Learning Resources, Inc. v. Trump Revisions: 2/23/26 (2026)

(Slip Opinion) OCTOBER TERM, 2025 1 Syllabus NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337. SUPREME COURT OF THE UNITED STATES Syllabus LEARNING RESOURCES, INC., ET AL. v. TRUMP, PRESIDENT OF THE UNITED STATES, ET AL. CERTIORARI BEFORE JUDGMENT TO THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT No. 24–1287. Argued November 5, 2025—Decided February 20, 2026* The question presented is whether the International Emergency Eco- nomic Powers Act (IEEPA) authorizes the President to impose tariffs. See 91 Stat. 1626. Shortly after taking office, President Trump sought to address two foreign threats: the influx of illegal drugs from Canada, Mexico, and China, Presidential Proclamation No. 10886, 90 Fed. Reg. 8327; Exec. Order No. 14193, 90 Fed. Reg. 9113; Exec. Order No. 14194, 90 Fed. Reg. 9117; Exec. Order No. 14195, 90 Fed. Reg. 9121, and “large and persistent” trade deficits, Exec. Order No. 14257, 90 Fed. Reg. 15041. The President determined that the drug influx had “created a public health crisis,” 90 Fed. Reg. 9113, and that the trade deficits had “led to the hollowing out” of the American manufacturing base and “undermined critical supply chains,” id., at 15041. The Pres- ident declared a national emergency as to both threats, deeming them “unusual and extraordinary,” and invoked his authority under IEEPA to respond. He imposed tariffs to deal with each threat. As to the drug traffick- ing tariffs, the President imposed a 25% duty on most Canadian and Mexican imports and a 10% duty on most Chinese imports. Id., at 9114, 9118, 9122–9123. As to the trade deficit (“reciprocal”) tariffs, the President imposed a duty “on all imports from all trading partners” of —————— *Together with No. 25–250, Trump, President of the United States, et al. v. V.O.S. Selections, Inc., et al., on certiorari to the United States Court of Appeals for the Federal Circuit. 2 LEARNING RESOURCES, INC. v. TRUMP Syllabus at least 10%, with dozens of nations facing higher rates. Id., at 15045, 15049. Since imposing each set of tariffs, the President has issued sev- eral increases, reductions, and other modifications. Petitioners in Learning Resources and respondents in V.O.S. Selec- tions filed suit, alleging that IEEPA does not authorize the reciprocal or drug trafficking tariffs. The Learning Resources plaintiffs—two small businesses—sued in the United States District Court for the Dis- trict of Columbia. That court denied the Government’s motion to transfer the case to the United States Court of International Trade (CIT) and granted the plaintiffs’ motion for a preliminary injunction, concluding that IEEPA did not grant the President the power to im- pose tariffs. The V.O.S. Selections plaintiffs—five small businesses and 12 States—sued in the CIT. That court granted summary judg- ment for the plaintiffs. And the Federal Circuit, sitting en banc, af- firmed in relevant part, concluding that IEEPA’s grant of authority to “regulate . . . importation” did not authorize the challenged tariffs, which “are unbounded in scope, amount, and duration.” 149 F. 4th 1312, 1338. The Government filed a petition for certiorari in V.O.S. Selections, and the Learning Resources plaintiffs filed a petition for certiorari before judgment. The Court granted the petitions and con- solidated the cases. Held: IEEPA does not authorize the President to impose tariffs. The judgment in No. 24–1287 is vacated, and the case is remanded with instructions to dismiss for lack of jurisdiction; the judgment in No. 25– 250 is affirmed. No. 24–1287, 784 F. Supp. 3d 209, vacated and remanded; No. 25–250, 149 F. 4th 1312, affirmed. THE CHIEF JUSTICE delivered the opinion of the Court with respect to Parts I and II–A–1: Article I, Section 8, of the Constitution specifies that “The Congress shall have Power To lay and collect Taxes, Duties, Imposts and Ex- cises.” The Framers recognized the unique importance of this taxing power—a power which “very clear[ly]” includes the power to impose tariffs. Gibbons v. Ogden, 9 Wheat. 1, 201. And they gave Congress “alone . . . access to the pockets of the people.” The Federalist No. 48, p. 310 (J. Madison). The Framers did not vest any part of the taxing power in the Executive Branch. See Nicol v. Ames, 173 U. S. 509, 515. The Government thus concedes that the President enjoys no inher- ent authority to impose tariffs during peacetime. It instead relies ex- clusively on IEEPA to defend the challenged tariffs. It reads the words “regulate” and “importation” to effect a sweeping delegation of Con- gress’s power to set tariff policy—authorizing the President to impose tariffs of unlimited amount and duration, on any product from any Cite as: 607 U. S. ___ (2026) 3 Syllabus country. 50 U. S. C. §1702(a)(1)(B). Pp. 5–7. THE CHIEF JUSTICE, joined by JUSTICE GORSUCH and JUSTICE BARRETT, concluded in Part II–A–2: The Court has long expressed “reluctan[ce] to read into ambiguous statutory text” extraordinary delegations of Congress’s powers. West Virginia v. EPA, 597 U. S. 697, 723 (quoting Utility Air Regulatory Group v. EPA, 573 U. S. 302, 324). In several cases described as in- volving “major questions,” the Court has reasoned that “both separa- tion of powers principles and a practical understanding of legislative intent” suggest Congress would not have delegated “highly consequen- tial power” through ambiguous language. Id., at 723–724. These con- siderations apply with particular force where, as here, the purported delegation involves the core congressional power of the purse. Con- gressional practice confirms as much. When Congress has delegated its tariff powers, it has done so in explicit terms and subject to strict limits. Against that backdrop of clear and limited delegations, the Govern- ment reads IEEPA to give the President power to unilaterally impose unbounded tariffs and change them at will. That view would represent a transformative expansion of the President’s authority over tariff pol- icy. It is also telling that in IEEPA’s half century of existence, no Pres- ident has invoked the statute to impose any tariffs, let alone tariffs of this magnitude and scope. That “ ‘lack of historical precedent,’ coupled with the breadth of authority” that the President now claims, suggests that the tariffs extend beyond the President’s “legitimate reach.” Na- tional Federation of Independent Business v. OSHA, 595 U. S. 109, 119 (quoting Free Enterprise Fund v. Public Company Accounting Over- sight Bd., 561 U. S. 477, 505). The “ ‘economic and political signifi- cance’ ” of the authority the President has asserted likewise “provide[s] a ‘reason to hesitate before concluding that Congress’ meant to confer such authority.” West Virginia, 597 U. S., at 721 (quoting FDA v. Brown & Williamson Tobacco Corp., 529 U. S. 120, 159–160). The stakes here dwarf those of other major questions cases. And as in those cases, “a reasonable interpreter would [not] expect” Congress to “pawn[ ]” such a “big-time policy call[ ] . . . off to another branch.” Biden v. Nebraska, 600 U. S. 477, 515 (BARRETT, J., concurring). There is no exception to the major questions doctrine for emergency statutes. Nor does the fact that tariffs implicate foreign affairs render the doctrine inapplicable. The Framers gave “Congress alone” the power to impose tariffs during peacetime. Merritt v. Welsh, 104 U. S. 694, 700. And the foreign affairs implications of tariffs do not make it any more likely that Congress would relinquish its tariff power through vague language, or without careful limits. Accordingly, the President must “point to clear congressional authorization” to justify 4 LEARNING RESOURCES, INC. v. TRUMP Syllabus his extraordinary assertion of that power. Nebraska, 600 U. S., at 506 (internal quotation marks omitted). He cannot. Pp. 7–13. THE CHIEF JUSTICE delivered the opinion of the Court with respect to Part II–B, concluding: (a) IEEPA authorizes the President to “investigate, block during the pendency of an investigation, regulate, direct and compel, nullify, void, prevent or prohibit . . . importation or exportation.” §1702(a)(1)(B). Absent from this lengthy list of specific powers is any mention of tariffs or duties. Had Congress intended to convey the distinct and extraor- dinary power to impose tariffs, it would have done so expressly, as it consistently has in other tariff statutes. The power to “regulate . . . importation” does not fill that void. The term “regulate,” as ordinarily used, means to “fix, establish, or control; to adjust by rule, method, or established mode; to direct by rule or re- striction; to subject to governing principles or laws.” Black’s Law Dic- tionary 1156. The facial breadth of this definition places in stark relief what ”regulate” is not usually thought to include: taxation. Many stat- utes grant the Executive the power to “regulate.” Yet the Government cannot identify any statute in which the power to regulate includes the power to tax. The Court is therefore skeptical that in IEEPA—and IEEPA alone—Congress hid a delegation of its birth-right power to tax within the quotidian power to “regulate.” While taxes may accomplish regulatory ends, it does not follow that the power to regulate includes the power to tax as a means of regula- tion. Indeed, when Congress addresses both the power to regulate and the power to tax, it does so separately and expressly. That it did not do so here is strong evidence that “regulate” in IEEPA does not include taxation. A contrary reading would render IEEPA partly unconstitutional. IEEPA authorizes the President to “regulate . . . importation or expor- tation.” §1702(a)(1)(B). But taxing exports is expressly forbidden by the Constitution. Art. I, §9, cl. 5. The “neighboring words” with which “regulate” “is associated” also suggest that Congress did not intend for “regulate” to include the rev- enue-raising power. United States v. Williams, 553 U. S. 285, 294. Each of the nine verbs in §1702(a)(1)(B) authorizes a distinct action a President might take in sanctioning foreign actors or controlling do- mestic actors engaged in foreign commerce, as Presidential practice confirms. And none of the listed authorities includes the distinct and extraordinary power to raise revenue—a power which no President has ever found in IEEPA. Pp. 14–16. (b) Several arguments marshaled in response are unpersuasive. First, the contention that IEEPA confers the power to impose tariffs because early commentators and the Court’s cases discuss tariffs in Cite as: 607 U. S. ___ (2026) 5 Syllabus the context of the Commerce Clause answers the wrong question. The question is not whether tariffs can ever be a means of regulating com- merce. It is instead whether Congress, when conferring the power to “regulate . . . importation,” gave the President the power to impose tar- iffs at his sole discretion. And Congress’s pattern of usage is plain: When Congress grants the power to impose tariffs, it does so clearly and with careful constraints. It did neither in IEEPA. Second, the argument that “regulate” naturally includes tariffs be- cause the term lies between two poles in IEEPA—“compel” on the af- firmative end and “prohibit” on the negative end—is unavailing. Alt- hough tariffs may be less extreme than an outright compulsion or prohibition, it does not follow that tariffs lie on the spectrum between those poles; they are different in kind, not degree, from the other au- thorities in IEEPA. Tariffs operate directly on domestic importers to raise revenue for the Treasury and are “very clear[ly] . . . a branch of the taxing power.” Gibbons, 9 Wheat., at 201. Thus, they fall outside the spectrum entirely. Third, the argument based on IEEPA’s predecessor, the Trading with the Enemy Act (TWEA), and the Court of Customs and Patent Appeals’ decision in United States v. Yoshida Int’l, Inc., 526 F. 2d 560, cannot bear the weight placed on it. A single, expressly limited opinion from a specialized intermediate appellate court does not establish a well-settled meaning that the Court can assume Congress incorpo- rated into IEEPA. Fourth, the historical argument based on the Court’s wartime prec- edents fails. Those precedents are facially inapposite, as all agree the President lacks inherent peacetime authority to impose tariffs. And the attenuated chain of inferences from wartime precedents through multiple iterations of TWEA to IEEPA cannot support—much less clearly support—a reading of IEEPA that includes the distinct power to impose tariffs. Finally, arguments relying on this Court’s precedents lack merit. Federal Energy Administration v. Algonquin SNG, Inc., 426 U. S. 548, bears little on the meaning of IEEPA. Section 232(b) of the Trade Ex- pansion Act of 1962 contains sweeping, discretion-conferring language that IEEPA does not contain, and the explicit reference to duties in Section 232(a) renders it natural for Section 232(b) itself to authorize duties. Nor does Dames & Moore v. Regan, 453 U. S. 654, offer support because that case was exceedingly narrow, did not address the Presi- dent’s power to “regulate,” and did not involve tariffs at all. Pp. 16– 20. JUSTICE KAGAN, joined by JUSTICE SOTOMAYOR and JUSTICE JACKSON, agreed that IEEPA does not authorize the President to im- pose tariffs, but concluded that the Court need not invoke the major 6 LEARNING RESOURCES, INC. v. TRUMP Syllabus questions doctrine because the ordinary tools of statutory interpreta- tion amply support that result. Pp. 1–7. JUSTICE JACKSON would also consult legislative history—in particu- lar, the House and Senate Reports that accompanied IEEPA and its predecessor statute, TWEA—to determine that Congress did not in- tend for IEEPA to authorize the Executive to impose tariffs. Pp. 1–5. ROBERTS, C. J., announced the judgment of the Court and delivered the opinion of the Court with respect to Parts I, II–A–1, and II–B, in which SOTOMAYOR, KAGAN, GORSUCH, BARRETT, and JACKSON, JJ., joined, and an opinion with respect to Parts II–A–2 and III, in which GORSUCH and BARRETT, JJ., joined. GORSUCH, J., and BARRETT, J., filed concurring opinions. KAGAN, J., filed an opinion concurring in part and concurring in the judgment, in which SOTOMAYOR and JACKSON, JJ., joined. JACKSON, J., filed an opinion concurring in part and concurring in the judgment. THOMAS, J., filed a dissenting opinion. KAVANAUGH, J., filed a dissenting opinion, in which THOMAS and ALITO, JJ., joined. Cite as: 607 U. S. ____ (2026) 1 Opinion of the Court NOTICE: This opinion is subject to formal revision before publication in the United States Reports. Readers are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, pio@supremecourt.gov, of any typographical or other formal errors. SUPREME COURT OF THE UNITED STATES _________________ Nos. 24–1287 and 25–250 _________________ LEARNING RESOURCES, INC., ET AL., PETITIONERS 24–1287 v. DONALD J. TRUMP, PRESIDENT OF THE UNITED STATES, ET AL. ON WRIT OF CERTIORARI BEFORE JUDGMENT TO THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT DONALD J. TRUMP, PRESIDENT OF THE UNITED STATES, ET AL., PETITIONERS 25–250 v. V.O.S. SELECTIONS, INC., ET AL. ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FEDERAL CIRCUIT [February 20, 2026] CHIEF JUSTICE ROBERTS announced the judgment of the Court and delivered the opinion of the Court, except as to Parts II–A–2 and III.* We decide whether the International Emergency Eco- nomic Powers Act (IEEPA) authorizes the President to im- pose tariffs. —————— *JUSTICE SOTOMAYOR, JUSTICE KAGAN, and JUSTICE JACKSON join only Parts I, II–A–1, and II–B of this opinion. 2 LEARNING RESOURCES, INC. v. TRUMP Opinion of the Court I A Shortly after taking office, President Trump sought to ad- dress two foreign threats. The first was the influx of illegal drugs from Canada, Mexico, and China. Presidential Proc- lamation No. 10886, 90 Fed. Reg. 8327 (2025); Exec. Order No. 14193, 90 Fed. Reg. 9113 (2025); Exec. Order No. 14194, 90 Fed. Reg. 9117 (2025); Exec. Order No. 14195, 90 Fed. Reg. 9121 (2025). The second was “large and persistent” trade deficits. Exec. Order No. 14257, 90 Fed. Reg. 15041 (2025). The President determined that the first threat had “created a public health crisis,” 90 Fed. Reg. 9113, and that the second had “led to the hollowing out” of the American manufacturing base and “undermined critical supply chains,” id., at 15041. He invoked his authority under IEEPA to respond. Enacted in 1977, IEEPA gives the President economic tools to address significant foreign threats. 91 Stat. 1626. When acting under IEEPA, the President must identify an “unusual and extraordinary threat” to American national security, foreign policy, or the economy, originating primar- ily “outside the United States.” 50 U. S. C. §1701(a). And he must “declare[ ] a national emergency” under the Na- tional Emergencies Act. Ibid.; see 90 Stat. 1255. He may then, “by means of instructions, licenses, or otherwise,” take the following actions to “deal with” the threat: “inves- tigate, block during the pendency of an investigation, regu- late, direct and compel, nullify, void, prevent or prohibit, any acquisition, holding, withholding, use, transfer, with- drawal, transportation, importation or exportation of, or dealing in, or exercising any right, power, or privilege with respect to, or transactions involving, any property in which any foreign country or a national thereof has any interest.” §§1701(a), 1702(a)(1)(B). President Trump declared a national emergency as to both the drug trafficking and the trade deficits, which he Cite as: 607 U. S. ____ (2026) 3 Opinion of the Court deemed “unusual and extraordinary” threats. He then im- posed tariffs to deal with each threat. As to the drug traf- ficking tariffs, the President imposed a 25% duty on most Canadian and Mexican imports and a 10% duty on most Chinese imports. 90 Fed. Reg. 9114, 9118, 9122–9123. As to the trade deficit (or “reciprocal”) tariffs, the President im- posed a duty “on all imports from all trading partners” of at least 10%. Id., at 15045. Dozens of nations faced higher rates. Id., at 15049. And these tariffs applied notwith- standing any extant trade agreements. Id., at 15045. Since imposing each set of tariffs, the President has is- sued several increases, reductions, and other modifications. One month after imposing the 10% drug trafficking tariffs on Chinese goods, he increased the rate to 20%. See Exec. Order No. 14228, 90 Fed. Reg. 11463 (2025). One month later, he removed a statutory exemption for Chinese goods under $800. Exec. Order No. 14256, 90 Fed. Reg. 14899 (2025). Less than a week after imposing the reciprocal tar- iffs, the President increased the rate on Chinese goods from 34% to 84%. Exec. Order No. 14259, 90 Fed. Reg. 15509 (2025). The very next day, he increased the rate further still, to 125%. Exec. Order No. 14266, 90 Fed. Reg. 15625, 15626 (2025). This brought the total effective tariff rate on most Chinese goods to 145%. The President has also shifted sets of goods into and out of the reciprocal tariff framework. See, e.g., Exec. Order No. 14360, 90 Fed. Reg. 54091 (2025) (exempting from reciprocal tariffs beef, fruits, coffee, tea, spices, and some fertilizers); Exec. Order No. 14346, 90 Fed. Reg. 43737 (2025). And he has issued a variety of other ad- justments. See, e.g., Exec. Order No. 14358, 90 Fed. Reg. 50729, 50730 (2025) (extending “the suspension of height- ened reciprocal tariffs” on Chinese imports). B Petitioners in Learning Resources and respondents in V.O.S. Selections filed suit, alleging that IEEPA does not 4 LEARNING RESOURCES, INC. v. TRUMP Opinion of the Court authorize the reciprocal or drug trafficking tariffs. The Learning Resources plaintiffs—two small businesses—sued in the United States District Court for the District of Co- lumbia. The V.O.S. Selections plaintiffs—five small busi- nesses and 12 States—sued in the United States Court of International Trade (CIT). The Government moved to transfer the Learning Re- sources case to the CIT. It argued that the District Court lacked jurisdiction under 28 U. S. C. §1581(i)(1), which gives the CIT “exclusive jurisdiction of any civil action com- menced against” the Government “that arises out of any law of the United States providing for . . . tariffs” or their “administration and enforcement.” The District Court de- nied that motion and granted the plaintiffs’ motion for a preliminary injunction, concluding that IEEPA did not grant the President the power to impose tariffs. 784 F. Supp. 3d 209 (DC 2025). In the V.O.S. Selections case, the CIT granted the plain- tiffs’ motion for summary judgment. 772 F. Supp. 3d 1350 (2025). The Federal Circuit, sitting en banc, affirmed in relevant part. 149 F. 4th 1312 (2025). It first concluded that the CIT had exclusive jurisdiction because the plain- tiffs’ claims arose out of modifications to the Harmonized Tariff Schedule of the United States (HTSUS). Id., at 1329. On the merits, it agreed with the CIT that IEEPA’s grant of authority to “regulate . . . importation” did not authorize the challenged tariffs, which “are unbounded in scope, amount, and duration.” Id., at 1338. Judge Cunningham concurred (for four judges), reasoning that IEEPA did not authorize the President to impose any tariffs. Id., at 1340. Judge Taranto dissented (for four judges), concluding that IEEPA authorized the challenged tariffs. Id., at 1348. The Government filed a motion to expedite and a petition for certiorari in V.O.S. Selections, and the Learning Re- sources plaintiffs filed a petition for certiorari before Cite as: 607 U. S. ____ (2026) 5 Opinion of the Court judgment. We granted the motion and petitions and con- solidated the cases. 606 U. S. 1050 (2025).1 II Based on two words separated by 16 others in Section 1702(a)(1)(B) of IEEPA—“regulate” and “importation”—the President asserts the independent power to impose tariffs on imports from any country, of any product, at any rate, for any amount of time. Those words cannot bear such weight. A 1 Article I, Section 8, of the Constitution sets forth the pow- ers of the Legislative Branch. The first Clause of that pro- vision specifies that “The Congress shall have Power To lay and collect Taxes, Duties, Imposts and Excises.” It is no accident that this power appears first. The power to tax was, Alexander Hamilton explained, “the most important of the authorities proposed to be conferred upon the Union.” The Federalist No. 33, pp. 202–203 (C. Rossiter ed. 1961). It is both a “power to destroy,” McCulloch v. Maryland, 4 Wheat. 316, 431 (1819), and a power “necessary to the ex- istence and prosperity of a nation”—“the one great power upon which the whole national fabric is based.” Nicol v. Ames, 173 U. S. 509, 515 (1899). —————— 1 We agree with the Federal Circuit that the V.O.S. Selections case falls within the exclusive jurisdiction of the CIT. The plaintiffs’ challenges “arise[ ] out of ” modifications to the HTSUS. 28 U. S. C. §1581(i)(1). Where, as here, such modifications are made under an “Act[ ] affecting import treatment,” 19 U. S. C. §2483, they are “considered to be statu- tory provisions of law for all purposes,” §3004(c)(1)(C). Thus, the plain- tiffs’ challenges “arise[ ] out of [a] law of the United States providing for . . . tariffs.” 28 U. S. C. §1581(i)(1). For the same reasons, the United States District Court for the District of Columbia lacked jurisdiction in the Learning Resources case. 6 LEARNING RESOURCES, INC. v. TRUMP Opinion of the Court The power to impose tariffs is “very clear[ly] . . . a branch of the taxing power.” Gibbons v. Ogden, 9 Wheat. 1, 201 (1824). “A tariff,” after all, “is a tax levied on imported goods and services.” Congressional Research Service (CRS), C. Casey, U. S. Tariff Policy: Overview 1 (2025). And tariffs “raise[ ] revenue,” West Lynn Creamery, Inc. v. Healy, 512 U. S. 186, 193 (1994)—the defining feature of a tax, United States v. Kahriger, 345 U. S. 22, 28, and n. 4 (1953); Sonzinsky v. United States, 300 U. S. 506, 514 (1937). In- deed, the Framers expected that the Government would for “a long time depend . . . chiefly on” tariffs for revenue. The Federalist No. 12, at 93 (A. Hamilton). Little wonder, then, that the First Congress’s first exercise of its taxing power (and its second enacted law, right after the one providing for the new officials to take an oath) was a tariff law. See Act of July 4, 1789, ch. 2, 1 Stat. 24. Recognizing the taxing power’s unique importance, and having just fought a revolution motivated in large part by “taxation without representation,” the Framers gave Con- gress “alone . . . access to the pockets of the people.” The Federalist No. 48, at 310 (J. Madison); see also Declaration of Independence ¶19. They required “All Bills for raising Revenue [to] originate in the House of Representatives.” U. S. Const., Art. I, §7, cl. 1. And in doing so, they ensured that only the House could “propose the supplies requisite for the support of government,” thereby reducing “all the overgrown prerogatives of the other branches.” The Feder- alist No. 58, at 359 (J. Madison). They did not vest any part of the taxing power in the Executive Branch. See Nicol, 173 U. S., at 515 (“[T]he whole power of taxation rests with Con- gress”). The Government thus concedes, as it must, that the Pres- ident enjoys no inherent authority to impose tariffs during peacetime. Tr. of Oral Arg. 70–71. And it does not defend the challenged tariffs as an exercise of the President’s warmaking powers. The United States, after all, is not at Cite as: 607 U. S. ____ (2026) 7 Opinion of ROBERTS, C. J. war with every nation in the world. The Government in- stead relies exclusively on IEEPA. It reads the words “reg- ulate” and “importation” to effect a sweeping delegation of Congress’s power to set tariff policy—authorizing the Pres- ident to impose tariffs of unlimited amount and duration, on any product from any country. 50 U. S. C. §1702(a)(1)(B). 2 We have long expressed “reluctan[ce] to read into ambig- uous statutory text” extraordinary delegations of Con- gress’s powers. West Virginia v. EPA, 597 U. S. 697, 723 (2022) (quoting Utility Air Regulatory Group v. EPA, 573 U. S. 302, 324 (2014)). In Biden v. Nebraska, 600 U. S. 477 (2023), for example, we declined to read authorization to “waive or modify” statutory or regulatory provisions appli- cable to financial assistance programs as a delegation of power to cancel $430 billion in student loan debt. Id., at 494 (quoting 20 U. S. C. §1098bb(a)(1)). In West Virginia v. EPA, we declined to read authorization to determine the “best system of emission reduction” as a delegation of power to force a nationwide transition away from the use of coal. 597 U. S., at 732 (quoting 42 U. S. C. §7411(a)(1)). And in National Federation of Independent Business v. OSHA, 595 U. S. 109 (2022) (per curiam), we declined to read authori- zation to ensure “safe and healthful working conditions” as a delegation of power to impose a vaccine mandate on 84 million Americans. Id., at 114, 117 (quoting 29 U. S. C. §651(b)); see also, e.g., Alabama Assn. of Realtors v. Depart- ment of Health and Human Servs., 594 U. S. 758, 764–765 (2021) (per curiam); King v. Burwell, 576 U. S. 473, 485– 486 (2015); Utility Air, 573 U. S., at 324. We have described several of these cases as “major ques- tions” cases. Nebraska, 600 U. S., at 505; West Virginia, 597 U. S., at 732; see also FDA v. Brown & Williamson To- bacco Corp., 529 U. S. 120, 159 (2000) (citing S. Breyer, 8 LEARNING RESOURCES, INC. v. TRUMP Opinion of ROBERTS, C. J. Judicial Review of Questions of Law and Policy, 38 Admin. L. Rev. 363, 370 (1986)). In each, the Government claimed broad, expansive power on an uncertain statutory basis. And in each, the statutory text might “[a]s a matter of defi- nitional possibilities” have been read to delegate the as- serted power. West Virginia, 597 U. S., at 732 (internal quotation marks omitted). But “context” counseled “skepti- cism.” Id., at 721, 732. That context included not just other language within the statute, but “constitutional structure” and “common sense.” Nebraska, 600 U. S., at 512, 515 (BARRETT, J., concurring). “[B]oth separation of powers principles and a practical understanding of legislative in- tent” suggested Congress would not have delegated “highly consequential power” through ambiguous language. West Virginia, 597 U. S., at 723–724. These considerations apply with particular force where, as here, the purported delegation involves the core congres- sional power of the purse. “Congress would likely . . . in- tend[ ] for itself ” the “basic and consequential tradeoffs,” id., at 730, inherent in uses of this “most complete and ef- fectual weapon,” The Federalist No. 58, at 359. And if Con- gress were to relinquish that weapon to another branch, a “reasonable interpreter” would expect it to do so “ ‘clearly.’ ” Nebraska, 600 U. S., at 514–515 (BARRETT, J., concurring) (quoting Utility Air, 573 U. S., at 324). What common sense suggests, congressional practice con- firms. When Congress has delegated its tariff powers, it has done so in explicit terms, and subject to strict limits. Congress has consistently used words like “duty” in stat- utes delegating authority to impose tariffs. (A customs “duty” is simply “the federal tax levied on goods shipped into the United States.” Black’s Law Dictionary 638 (12th ed. 2024).) See, e.g., 19 U. S. C. §1338(d) (“rates of duty”); §2132(a) (“temporary import surcharge . . . in the form of duties”); §2253(a)(3)(A) (“duty on the imported article”); §2411(c)(1)(B) (“duties or other import restrictions”). It has Cite as: 607 U. S. ____ (2026) 9 Opinion of ROBERTS, C. J. capped the amount and duration of tariffs. See, e.g., §1338(d) (50% cap); §2132(a) (15% cap, 150-day time limit); §2253(e) (50% cap, phasedown requirement after one year). And it has conditioned exercise of the tariff power on de- manding procedural prerequisites. See, e.g., §2252 (inves- tigation by the United States International Trade Commis- sion, public hearings, report of findings and recommendation); §§2411–2414 (investigation by the United States Trade Representative, consultation with rel- evant country and interested parties, publication of find- ings).2 Against this backdrop of clear and limited delegations, the Government reads IEEPA to give the President power to unilaterally impose unbounded tariffs. On this reading, moreover, the President is unconstrained by the significant procedural limitations in other tariff statutes and free to issue a dizzying array of modifications at will. See supra, at 3. All it takes to unlock that extraordinary power is a Presidential declaration of emergency, which the Govern- ment asserts is unreviewable. Brief for Federal Parties 42. And the only way of restraining the exercise of that power is a veto-proof majority in Congress. See 50 U. S. C. §1622(a)(1) (requiring a “joint resolution” “enacted into law” to terminate a national emergency). That view, if credited, would “represent[ ] a ‘transformative expansion’ ” of the President’s authority over tariff policy, West Virginia, 597 —————— 2 The same is true of Section 232 of the Trade Expansion Act of 1962, 76 Stat. 877, which we have held authorizes sector-specific import “li- cense fee[s].” Federal Energy Administration v. Algonquin SNG, Inc., 426 U. S. 548, 571 (1976). Section 232(a) expressly references “duties.” 19 U. S. C. §1862(a); see infra, at 19. And Section 232(c) authorizes the President to “adjust the imports” of an “article,” §1862(c), but only after the Secretary of Commerce, in consultation with the Secretary of De- fense, conducts an investigation and prepares a report finding that the “article is being imported into the United States in such quantities or under such circumstances as to threaten to impair the national security,” §1862(b). 10 LEARNING RESOURCES, INC. v. TRUMP Opinion of ROBERTS, C. J. U. S., at 724 (quoting Utility Air, 573 U. S., at 324), and in- deed—as demonstrated by the exercise of that authority in this case—over the broader economy as well. See Congres- sional Budget Office, CBO’s Current View of the Economy From 2025 to 2028, p. 5 (Sept. 2025); Brief for Federal Par- ties 2–3. It would replace the longstanding executive-legis- lative collaboration over trade policy with unchecked Pres- idential policymaking. See CRS, Trade Promotion Authority (TPA) and the Role of Congress in Trade Policy (2015). Congress seldom effects such sea changes through “vague language.” West Virginia, 597 U. S., at 724. It is also telling that in IEEPA’s “half century of exist- ence,” no President has invoked the statute to impose any tariffs—let alone tariffs of this magnitude and scope. Na- tional Federation of Independent Business, 595 U. S., at 119.3 Presidents have, by contrast, regularly invoked IEEPA for other purposes. CRS, C. Casey, J. Elsea, & L. Rosen, The International Emergency Economic Powers Act: Origins, Evolution, and Use 18–21 (2025). At the same time, they have invoked other statutes—but never IEEPA—to impose tariffs, on products ranging from car tires to washing machines. See, e.g., Presidential Procla- mation No. 8414, 3 CFR 115 (2009 Comp.); Presidential —————— 3 Indeed, even before IEEPA was enacted, only one President relied on its predecessor, the Trading with the Enemy Act (TWEA), ch. 106, 40 Stat. 411, to impose tariffs—and then only as a post hoc defense to a legal challenge. See Presidential Proclamation No. 4074, 36 Fed. Reg. 15724 (1971) (initially invoking the Tariff Act of 1930 and Trade Expansion Act of 1962); United States v. Yoshida Int’l, Inc., 526 F. 2d 560, 572 (CCPA 1975). Those tariffs were also of limited amount, duration, and scope. See id., at 568–569, 577–578 (noting that the 10-percent surcharge was described by President Nixon as “ ‘a temporary measure,’ ” was in effect less than five months, applied only to “articles which had been the sub- ject of prior tariff concessions,” and was capped at congressionally au- thorized rates); Economic Report of the President 70 (1972) (“When all exceptions to the 10-percent rule were taken into account, the effective rate of surcharge came down to 4.8 percent”). Cite as: 607 U. S. ____ (2026) 11 Opinion of ROBERTS, C. J. Proclamation No. 9694, 83 Fed. Reg. 3553 (2018). And those tariffs did not “even beg[in] to approach the size or scope” of the IEEPA tariffs at issue here. Nebraska, 600 U. S., at 502 (quoting Alabama Assn., 594 U. S., at 765). The “ ‘lack of historical precedent’ ” for the IEEPA tariffs, “coupled with the breadth of authority” that the President now claims, “is a ‘telling indication’ ” that the tariffs extend beyond the President’s “legitimate reach.” National Feder- ation of Independent Business, 595 U. S., at 119 (quoting Free Enterprise Fund v. Public Company Accounting Over- sight Bd., 561 U. S. 477, 505 (2010)). The “ ‘economic and political significance’ ” of the author- ity the President has asserted likewise “provide[s] a ‘reason to hesitate before concluding that Congress’ meant to confer such authority.” West Virginia, 597 U. S., at 721 (quoting Brown & Williamson, 529 U. S., at 159–160). The Presi- dent’s assertion here of broad “statutory power over the na- tional economy” is “extravagant” by any measure. Utility Air, 573 U. S., at 324. And as the Government admits— indeed, boasts—the economic and political consequences of the IEEPA tariffs are astonishing. The Government points to projections that the tariffs will reduce the national deficit by $4 trillion, and that international agreements reached in reliance on the tariffs could be worth $15 trillion. Brief for Federal Parties 3, 11. In the President’s view, whether “we are a rich nation” or a “poor” one hangs in the balance. Id., at 2. These stakes dwarf those of other major questions cases. See, e.g., Nebraska, 600 U. S., at 483 ($430 billion); Alabama Assn., 594 U. S., at 764 (nearly $50 billion); West Virginia, 597 U. S., at 714 (“billions of dollars in compliance costs”). As in those cases, “a reasonable interpreter would [not] expect” Congress to “pawn[ ]” such a “big-time policy call[ ] . . . off to another branch.” Nebraska, 600 U. S., at 515 (BARRETT, J., concurring). 12 LEARNING RESOURCES, INC. v. TRUMP Opinion of ROBERTS, C. J. The Government and the principal dissent attempt to avoid application of the major questions doctrine on several grounds. None is convincing. The Government argues first that the doctrine should not apply to emergency statutes. Brief for Federal Parties 35– 36. But this argument is nearly identical to one it already advanced in Nebraska. There, the Government contended that a different emergency statute should be interpreted broadly because its “whole point” was to provide “substan- tial discretion to . . . respond to unforeseen emergencies.” 600 U. S., at 500 (internal quotation marks omitted). We rejected that argument in Nebraska, and we reject it here as well. “Emergency powers,” after all, “tend to kindle emergencies.” Youngstown Sheet & Tube Co. v. Sawyer, 343 U. S. 579, 650 (1952) (Jackson, J., concurring). Dozens of IEEPA emergencies remain ongoing today, including the first—declared over four decades ago in response to the Ira- nian hostage crisis. CRS, Casey, International Emergency Economic Powers Act, at 20. And as the Framers under- stood, emergencies can “afford a ready pretext for usurpa- tion” of congressional power. Youngstown, 343 U. S., at 650 (Jackson, J., concurring). Where Congress has reason to be worried about its powers “slipping through its fingers,” id., at 654, we in turn have every reason to expect Congress to use clear language to effectuate unbounded delegations— particularly of its “one great power,” Nicol, 173 U. S., at 515. The Government’s and the principal dissent’s proposed foreign affairs exception fares no better. Brief for Federal Parties 34–35; post, at 45–57 (opinion of KAVANAUGH, J.). As a general matter, the President of course enjoys some “independent constitutional power[s]” over foreign affairs “even without congressional authorization.” FCC v. Con- sumers’ Research, 606 U. S. 656, 707 (2025) (KAVANAUGH, J., concurring). And Congress certainly may intend to “give the President substantial authority and flexibility” in many Cite as: 607 U. S. ____ (2026) 13 Opinion of ROBERTS, C. J. foreign affairs or national security contexts. Post, at 48 (opinion of KAVANAUGH, J.) (quoting Consumers’ Research, 606 U. S., at 706 (KAVANAUGH, J., concurring)). But “flip[ping]” the “presumption” under the major questions doctrine, Brief for Federal Parties 34, makes little sense when it comes to tariffs. As the Government admits, the President and Congress do not “enjoy concurrent constitu- tional authority” to impose tariffs during peacetime. Ibid.; Tr. of Oral Arg. 70–71. The Framers gave that power to “Congress alone”—notwithstanding the obvious foreign af- fairs implications of tariffs. Merritt v. Welsh, 104 U. S. 694, 700 (1882). And whatever may be said of other powers that implicate foreign affairs, we would not expect Congress to relinquish its tariff power through vague language, or with- out careful limits. The central thrust of the Government’s and the principal dissent’s proposed exceptions appears to be that ambiguous delegations in statutes addressing “the most major of major questions” should necessarily be construed broadly. Brief for Federal Parties 35. But it simply does not follow from the fact that a statute deals with major problems that it should be read to delegate all major powers for which there may be a “colorable textual basis.” West Virginia, 597 U. S., at 722. It is in precisely such cases that we should be alert to claims that sweeping delegations—particularly delega- tions of core congressional powers—“lurk[ ]” in “ambiguous statutory text.” Id., at 723 (internal quotation marks omit- ted). There is no major questions exception to the major questions doctrine. Accordingly, the President must “point to clear congres- sional authorization” to justify his extraordinary assertion of the power to impose tariffs. Nebraska, 600 U. S., at 506 (internal quotation marks omitted). He cannot. 14 LEARNING RESOURCES, INC. v. TRUMP Opinion of the Court B To begin, IEEPA authorizes the President to “investigate, block during the pendency of an investigation, regulate, di- rect and compel, nullify, void, prevent or prohibit . . . impor- tation or exportation.” 50 U. S. C. §1702(a)(1)(B). Absent from this lengthy list of powers is any mention of tariffs or duties. That omission is notable in light of the significant but specific powers Congress did go to the trouble of nam- ing. It stands to reason that had Congress intended to con- vey the distinct and extraordinary power to impose tariffs, it would have done so expressly—as it consistently has in other tariff statutes. See supra, at 8; accord, post, at 11, 26– 27 (opinion of KAVANAUGH, J.). The power to “regulate . . . importation” does not fill that void. “Regulate,” as that term is ordinarily used, means to “fix, establish, or control; to adjust by rule, method, or es- tablished mode; to direct by rule or restriction; to subject to governing principles or laws.” Black’s Law Dictionary 1156 (5th ed. 1979); see also Ysleta del Sur Pueblo v. Texas, 596 U. S. 685, 697 (2022). This definition captures much of what a government does on a day-to-day basis. Indeed, if “regulate” is as broad as the principal dissent suggests, post, at 10–11, then the other eight verbs in §1702(a)(1)(B) are simply wasted ink. But the facial breadth of “regulate” places in stark relief what the term is not usually thought to include: taxation. The U. S. Code is replete with statutes granting the Executive the authority to “regulate” someone or something. Yet the Government cannot identify any statute in which the power to regulate includes the power to tax. The Government concedes, for example, that the Se- curities and Exchange Commission cannot tax the trading of securities, even though it is expressly authorized to “reg- ulate the trading of . . . securities.” 15 U. S. C. §78i(h)(1); see Brief for Federal Parties 31–32. We are therefore skep- tical that in IEEPA—and IEEPA alone—Congress hid a Cite as: 607 U. S. ____ (2026) 15 Opinion of the Court delegation of its birth-right power to tax within the quotid- ian power to “regulate.” Taxes, to be sure, may accomplish regulatory ends. See Sonzinsky, 300 U. S., at 513; Gibbons, 9 Wheat., at 201– 202. But it does not follow that the power to regulate some- thing includes the power to tax it as a means of regulation. Congressional practice suggests as much. When Congress addresses both the power to regulate and the power to tax, it does so separately and expressly. See, e.g., 16 U. S. C. §460bbb–9(a) (distinguishing between the power to “tax persons, franchise, or private property” on lands and the power “to regulate the private lands”); 2 U. S. C. §622(8)(B)(i) (“government-sponsored enterprise” does not have the “power to tax or to regulate interstate commerce”). That is unsurprising, as the “power to regulate commerce” is “entirely distinct from the right to levy taxes.” Gibbons, 9 Wheat., at 201. That Congress did not grant those au- thorities separately here is strong evidence that “regulate” in IEEPA does not include taxation. A contrary reading would render IEEPA partly unconsti- tutional. IEEPA authorizes the President to “regulate . . . importation or exportation.” 50 U. S. C. §1702(a)(1)(B) (em- phasis added). Taxing exports, however, is expressly for- bidden by the Constitution. Art. I, §9, cl. 5. The “neighboring words” with which “regulate” “is asso- ciated” also suggest that Congress did not intend for “regu- late” to include the revenue-raising power. United States v. Williams, 553 U. S. 285, 294 (2008). “Regulate” is one of nine verbs listed in §1702(a)(1)(B). Each authorizes a dis- tinct action a President might take in sanctioning foreign actors or controlling domestic actors engaged in foreign commerce—blocking imports, for example, or prohibiting transactions. Presidential practice under IEEPA demon- strates as much. See CRS, Casey, International Emergency Economic Powers Act, at 79–106 (Table A–3); see, e.g., Exec. Order No. 13194, 3 CFR 741 (2001 Comp.) (blocking 16 LEARNING RESOURCES, INC. v. TRUMP Opinion of the Court importation of diamonds from insurgent regime in Sierra Leone); Exec. Order No. 12947, 3 CFR 319 (1995 Comp.) (prohibiting transactions with those “who threaten to dis- rupt the Middle East peace process”). None of IEEPA’s au- thorities includes the distinct and extraordinary power to raise revenue. And the fact that no President has ever found such power in IEEPA is strong evidence that it does not exist. See supra, at 10; FTC v. Bunte Brothers, Inc., 312 U. S. 349, 351–352 (1941). We do not attempt to set forth the metes and bounds of the President’s authority to “regulate . . . importation” un- der IEEPA. That “interpretive question” is “not at issue” in this case, and any answer would be “plain dicta.” West Vir- ginia, 597 U. S., at 734–735, and n. 5. Our task today is to decide only whether the power to “regulate . . . importa- tion,” as granted to the President in IEEPA, embraces the power to impose tariffs. It does not.4 The Government, echoed point-for-point by the principal dissent, marshals several arguments in response. First, it contends that IEEPA confers the power to impose tariffs be- cause early commentators and this Court’s cases discuss tariffs in the context of the Constitution’s Commerce Clause. See Brief for Federal Parties 24–25; post, at 12–13 (opinion of KAVANAUGH, J.). But that answers the wrong question. The question is not, as the Government would have it, whether tariffs can ever be a means of regulating commerce. It is instead whether Congress, when conferring the power to “regulate . . . importation,” gave the President the power to impose tariffs at his sole discretion. And —————— 4 The principal dissent surmises that the President could impose “most if not all” of the tariffs at issue under statutes other than IEEPA. Post, at 62 (opinion of KAVANAUGH, J.). The cited statutes contain various com- binations of procedural prerequisites, required agency determinations, and limits on the duration, amount, and scope of the tariffs they author- ize. See supra, at 8–9; post, at 62–63. We do not speculate on hypothet- ical cases not before us. Cite as: 607 U. S. ____ (2026) 17 Opinion of the Court Congress’s pattern of usage is most relevant to answering that question. That pattern is plain: When Congress grants the power to impose tariffs, it does so clearly and with care- ful constraints. It did neither here. The Government raises another contextual argument. Because “regulate” “lies between” two “poles” in IEEPA— “compel” on the affirmative end and “prohibit” on the nega- tive end—the term naturally includes the “less extreme, more flexible” tool of tariffs. Reply Brief 9 (internal quota- tion marks omitted); see post, at 29–30 (opinion of KAVANAUGH, J.) (making a greater-includes-the-lesser ar- gument). But tariffs, as discussed above, are different in kind, not degree, from the other authorities in IEEPA. Un- like those authorities, tariffs operate directly on domestic importers to raise revenue for the Treasury. See 19 U. S. C. §1505(a); 19 CFR §141.1(b) (2025). Even though a tariff is, in some sense, “less extreme” than an outright compulsion or prohibition, it does not follow that tariffs lie on the spec- trum between those poles. They are instead “very clear[ly] . . . a branch of the taxing power,” Gibbons, 9 Wheat., at 201, and fall outside the spectrum entirely. Finding no support in the statute the President invoked, the Government turns to one he did not: IEEPA’s predeces- sor, TWEA. Ch. 106, 40 Stat. 411. In 1975, the Court of Customs and Patent Appeals held that the authority to “regulate . . . importation” in TWEA authorized President Nixon to impose limited tariffs. United States v. Yoshida Int’l, Inc., 526 F. 2d 560, 572, 577–578. When Congress en- acted IEEPA two years later, the Government contends, it conveyed that same authority (except without the limits). See also post, at 14–17 (opinion of KAVANAUGH, J.). This argument cannot bear the weight the Government places on it. While this Court sometimes assumes that Con- gress incorporates judicial definitions into legislation, we do so “only when [the] term’s meaning was ‘well-settled’ ” be- fore the adoption. Kemp v. United States, 596 U. S. 528, 18 LEARNING RESOURCES, INC. v. TRUMP Opinion of the Court 539 (2022) (quoting Neder v. United States, 527 U. S. 1, 22 (1999)); see also United States v. Kwai Fun Wong, 575 U. S. 402, 412–415 (2015). A single, expressly limited opinion from a specialized intermediate appellate court does not clear that hurdle.5 See BP p.l.c. v. Mayor and City Council of Baltimore, 593 U. S. 230, 244 (2021). The tariff authority asserted by President Nixon, moreover, was “far removed” from TWEA’s “original purposes” of sanctioning foreign bel- ligerents. Cohen, Fundamentals of U. S. Foreign Trade Pol- icy, at 178–179. We are therefore skeptical that Congress enacted IEEPA with an eye toward granting that novel power. The Government has another historical argument based on this Court’s wartime precedents. See generally Brief for Professor Aditya Bamzai as Amicus Curiae; Reply Brief 9– 11, 18. According to the Government, those precedents acknowledge an inherent Presidential power to impose tar- iffs during armed conflict. And, the argument goes, Con- gress in TWEA, and then in IEEPA, codified those prece- dents. But this argument fails at both steps. Insofar as the Government relies on our wartime cases themselves, they are facially inapposite. Regardless of what they might mean for the President’s inherent wartime authority, all —————— 5 The Government, citing the IEEPA House Committee Report, con- tends that Congress “indisputably knew of ” Yoshida’s interpretation of TWEA. Brief for Federal Parties 26; see also post, at 15–16, and n. 11 (opinion of KAVANAUGH, J.). But even taking the Report at face value, it hardly helps the Government. The Report explains that “[s]uccessive Presidents have seized upon the open-endedness of [TWEA] section 5(b) to turn that section, through usage, into something quite different from what was envisioned in 1917.” H. R. Rep. No. 95–459, pp. 8–9 (1977); accord, S. Cohen, R. Blecker, & P. Whitney, Fundamentals of U. S. For- eign Trade Policy 178–179 (2d ed. 2003). That is not exactly a stamp of approval on the action Yoshida guardedly endorsed. And in any event, the Government’s “knew of ” standard falls well short of the “broad and unquestioned” “judicial consensus” we have required to conclude that Congress incorporated a judicial definition into a statutory term. Jama v. Immigration and Customs Enforcement, 543 U. S. 335, 349 (2005). Cite as: 607 U. S. ____ (2026) 19 Opinion of the Court agree that the President has no inherent peacetime author- ity to impose tariffs. Nor are we persuaded that the dots connect from our war- time precedents, through multiple iterations of TWEA, to IEEPA, such that IEEPA should be interpreted to grant the President an expansive peacetime tariff power. This argu- ment relies extensively on a series of inferences drawn from scant legislative history. Such an attenuated chain cannot support—much less “clearly” support—a reading of IEEPA that includes the distinct power to impose tariffs. Alabama Assn., 594 U. S., at 764. Turning to this Court’s precedents, the Government first relies on Federal Energy Administration v. Algonquin SNG, Inc., 426 U. S. 548 (1976). There, we held that Section 232(b) of the Trade Expansion Act of 1962, which allows the President to “adjust the imports” of particular goods to pro- tect national security, includes the power to impose “license fees.” Id., at 561. But that holding bears little on the mean- ing of IEEPA. As a textual matter, Section 232(b) author- izes the President not only to “adjust . . . imports,” but (as the Government emphasized in Algonquin) to “take such ac- tion . . . as he deems necessary” to adjust the imports of a good. Brief for Petitioners 26 (emphasis in original) and Tr. of Oral Arg. 6–7, in Federal Energy Administration v. Al- gonquin SNG, Inc., O. T. 1975, No. 75–382. IEEPA does not contain such sweeping, discretion-conferring language. As for context, Section 232(a) states that “[n]o action shall be taken” to “decrease or eliminate” an existing “duty or other import restriction” if doing so would threaten national se- curity. 19 U. S. C. §1862(a) (1970 ed.). This explicit refer- ence to duties preceding Section 232(b) renders it natural for Section 232(b) itself to authorize duties. Thus, we de- cline to extend Algonquin’s expressly “limited” holding any further. 426 U. S., at 571. Finally, the Government invokes Dames & Moore v. Re- gan, 453 U. S. 654 (1981), but that case offers no support. 20 LEARNING RESOURCES, INC. v. TRUMP Opinion of ROBERTS, C. J. Dames & Moore was exceedingly narrow,6 did not address the President’s power to “regulate,” and did not involve tar- iffs at all. If anything, that case highlights the importance of close attention to IEEPA’s text. “The terms of . . . IEEPA,” we held, “do not authorize” the suspension of claims. Id., at 675. So too here; the terms of IEEPA do not authorize tariffs. III The President asserts the extraordinary power to unilat- erally impose tariffs of unlimited amount, duration, and scope. In light of the breadth, history, and constitutional context of that asserted authority, he must identify clear congressional authorization to exercise it. IEEPA’s grant of authority to “regulate . . . importation” falls short. IEEPA contains no reference to tariffs or duties. The Government points to no statute in which Congress used the word “regulate” to authorize taxation. And until now no President has read IEEPA to confer such power. We claim no special competence in matters of economics or foreign affairs. We claim only, as we must, the limited role assigned to us by Article III of the Constitution. Ful- filling that role, we hold that IEEPA does not authorize the President to impose tariffs. —————— 6 See, e.g., 453 U. S., at 660 (“We are confined to a resolution of the dispute presented to us”); ibid. (We are “acutely aware of the necessity to rest decision on the narrowest possible ground capable of deciding the case”); id., at 661 (“We attempt to lay down no general ‘guidelines’ cover- ing other situations not involved here, and attempt to confine the opinion only to the very questions necessary to decision of the case”); ibid. (“[T]he decisions of the Court in this area have been rare, episodic, and afford little precedential value for subsequent cases”); id., at 688 (“[W]e re-em- phasize the narrowness of our decision”). This is not quite “no, no, a thousand times no,” but should have sufficed to dissuade the principal dissent from invoking the case, see post, at 55–56, with respect to the quite distinct legal and factual issues present here. Cite as: 607 U. S. ____ (2026) 21 Opinion of the Court The judgment of the United States Court of Appeals for the Federal Circuit in case No. 25–250 is affirmed. The judgment of the United States District Court for the Dis- trict of Columbia in case No. 24–1287 is vacated, and the case is remanded with instructions to dismiss for lack of ju- risdiction. It is so ordered. Cite as: 607 U. S. ____ (2026) 1 GORSUCH, J., concurring SUPREME COURT OF THE UNITED STATES _________________ Nos. 24–1287 and 25–250 _________________ LEARNING RESOURCES, INC., ET AL., PETITIONERS 24–1287 v. DONALD J. TRUMP, PRESIDENT OF THE UNITED STATES, ET AL. ON WRIT OF CERTIORARI BEFORE JUDGMENT TO THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT DONALD J. TRUMP, PRESIDENT OF THE UNITED STATES, ET AL., PETITIONERS 25–250 v. V.O.S. SELECTIONS, INC., ET AL. ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FEDERAL CIRCUIT [February 20, 2026] JUSTICE GORSUCH, concurring. The President claims that Congress delegated to him an extraordinary power in the International Emergency Eco- nomic Powers Act (IEEPA)—the power to impose tariffs on practically any products he wants, from any countries he chooses, in any amounts he selects. Applying the major questions doctrine, the principal opinion rejects that argu- ment. I join in full. The Constitution lodges the Nation’s lawmaking powers in Congress alone, and the major ques- tions doctrine safeguards that assignment against execu- tive encroachment. Under the doctrine’s terms, the Presi- dent must identify clear statutory authority for the extraordinary delegated power he claims. And, as the prin- cipal opinion explains, that is a standard he cannot meet. 2 LEARNING RESOURCES, INC. v. TRUMP GORSUCH, J., concurring Whatever else might be said about Congress’s work in IEEPA, it did not clearly surrender to the President the sweeping tariff power he seeks to wield. Not everyone sees it this way. Past critics of the major questions doctrine do not object to its application in this case, and they even join much of today’s principal opinion. But, they insist, they can reach the same result by employ- ing only routine tools of statutory interpretation. Post, at 1 (KAGAN, J., joined by SOTOMAYOR and JACKSON, JJ., con- curring in part and concurring in judgment). Meanwhile, one colleague who joins the principal opinion in full sug- gests the major questions doctrine is nothing more than routine statutory interpretation. Post, at 1 (BARRETT, J., concurring). Still others who have joined major questions decisions in the past dissent from today’s application of the doctrine. Post, at 1 (KAVANAUGH, J., joined by THOMAS and ALITO, JJ., dissenting). Finally, seeking to sidestep the ma- jor questions doctrine altogether, one colleague submits that Congress may hand over to the President most of its powers, including the tariff power, without limit. Post, at 1–2 (THOMAS, J., dissenting). It is an interesting turn of events. Each camp warrants a visit. I Start with the critics. In the past, they have criticized the major questions doctrine for two main reasons. The doc- trine, they have suggested, is a novelty without basis in law. West Virginia v. EPA, 597 U. S. 697, 779 (2022) (KAGAN, J., joined by, inter alios, SOTOMAYOR, J., dissent- ing) (calling the doctrine a “special cano[n]” that has “mag- ically appear[ed]”). And, they have argued, the doctrine is rooted in an “anti-administrative-state stance” that pre- vents Congress from employing executive agency officials to “d[o] important work.” Id., at 780. Today, the critics pro- ceed differently. They join a section of the principal opinion that applies the major questions doctrine. Ante, at 14–20. Cite as: 607 U. S. ____ (2026) 3 GORSUCH, J., concurring And rather than critique the doctrine, they say only that it is “unnecessary” in this case “because ordinary principles of statutory interpretation lead to the same result.” Post, at 2–3 (opinion of KAGAN, J.). A Unpack that last claim first. My concurring colleagues contend that, as a matter of “straight-up statutory construc- tion,” IEEPA does