Background
On February 20, 2026, the Supreme Court held that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. Learning Res., Inc. v. Trump, 607 U.S. 229, 255 (2026). The Supreme Court did not itself order refunds; the U.S. Court of International Trade (CIT) did, including an April 17 order directing U.S. Customs and Border Protection (CBP) to liquidate unliquidated IEEPA entries without those duties and to reliquidate liquidated entries without them, while suspending immediate compliance. Order at 3, V.O.S. Selections, Inc. v. United States, No. 25-00066, ECF No. 82 (Ct. Int’l Trade Apr. 17, 2026). CBP deployed Phase 1 of its Consolidated Administration and Processing of Entries (CAPE) functionality in ACE on April 20 for certain unliquidated entries and entries liquidated within the preceding 80 days, and Phase 2 followed on June 29 for entries flagged for reconciliation for which no Type 09 reconciliation entry had been