On March 4, 2026, Judge Richard K. Eaton of the U.S. Court of International Trade issued a three-page order in Atmus Filtration, Inc. v. United States that carries consequences far beyond the single plaintiff in that case.
What the Order Says
Judge Eaton directed U.S. Customs and Border Protection to do two things immediately:
- Liquidate all unliquidated entries that were subject to IEEPA duties — without applying those duties.
- Reliquidate any liquidated entries for which liquidation is not yet final — again, without the IEEPA duties.
The order flows directly from the Supreme Court’s February 20, 2026, ruling in Learning Resources, Inc. v. Trump, which held that IEEPA-based tariffs were unauthorized. Judge Eaton was explicit: “All importers of record whose entries were subject to IEEPA duties are entitled to the benefit of the Learning Resources decision.”
Why This Order Has National Reach
The government argued that the Supreme Court’s 2025 ruling in Trump v. CASA, Inc. — which prohibited universal injunctions — should limit the order’s scope. Judge Eaton rejected that argument directly. The CIT was established by Congress in 1980 with national geographic jurisdiction and exclusive subject matter jurisdiction over import disputes. The CASA ruling, he held, governs federal district courts operating under the Judiciary Act of 1789 — not the CIT, which operates under an entirely different statutory framework.
He also noted that the Chief Judge has designated him as the sole judge to hear all IEEPA refund cases. There is no risk of conflicting rulings within the court.
What This Means for Your Business
If your company imported goods subject to IEEPA tariffs and your entries are unliquidated or not yet finally liquidated, CBP is now under a court order to process those entries without the tariff burden. You may not need to do anything — but you need to know your entry status now. If your entry liquidates going forward, monitor it closely to confirm that CBP is complying with Judge Eaton’s order.
If your entries have already been finally liquidated, the picture is more complex. The 180-day protest window under 19 U.S.C. § 1514 governs your path to a refund, and that clock may have already run. That is a separate legal question.
The Bottom Line
Judge Eaton’s order is the most significant customs ruling since Learning Resources itself. It confirms that the CIT views the refund obligation as broad, uniform, and not subject to the universal injunction limitations that have constrained other courts. For importers, the message is simple: know your liquidation status, and act now.
