The U.S. government has begun denying requests from companies seeking refunds for billions of dollars in illegal tariffs, despite a landmark Supreme Court ruling that struck down the levies last month.
Customs officials are rejecting "Post Summary Corrections" and suspending protests filed by importers, according to people familiar with the matter, escalating a legal battle over more than $130 billion in collected duties.
The standoff follows a February 20, 2026, Supreme Court decision in Learning Resources Inc. v. Trump, which ruled 6-3 that the International Emergency Economic Powers Act (IEEPA) does not grant the president authority to impose revenue-raising tariffs.
While the court dismantled the legal basis for the "Liberation Day" and "Reciprocal" tariffs, it provided no specific roadmap for reimbursements, leaving a vacuum that the Trump administration has moved to fill with further litigation and new, alternative duties.
On Wednesday, Judge Richard K. Eaton of the U.S. Court of International Trade (CIT) attempted to force the government’s hand, ordering U.S. Customs and Border Protection (CBP) to begin liquidating millions of entries without the illegal duties.
Judge Eaton asserted that "all importers of record" are entitled to the benefit of the ruling, including interest.
However, the administration has signaled it will appeal the order, arguing that refunds are not automatic and must be litigated on a case-by-case basis—a process that could stretch into 2028 or beyond.
The fiscal stakes are massive. Economic models from the Penn Wharton Budget Model suggest the U.S. Treasury could be on the hook for up to $175 billion when interest is included.
As the government resists payouts, President Trump has already pivoted to Section 122 of the Trade Act of 1974 to impose a new 10% global baseline tariff, a move seen by some analysts as a strategy to raise the very revenue needed to cover potential court-ordered refunds.