Learning Resources, Inc. v. Trump (2026): The Major Questions Doctrine

By Ben Pope — March 23, 2026

Introduction

On February 20, 2026, the landmark case Learning Resources, Inc. v. Trump (2026) was decided, striking down a series of executive orders enacted by President Trump to levy sweeping tariffs on goods from across the globe. Initially framed on the grounds of a national emergency, President Trump enacted the International Emergency Economic Powers Act, 50 U.S.C. § 1701 (IEEPA) to tariff goods coming from China, Canada, and Mexico. Then on April 2, 2025, he declared what he called “Liberation Day” in which these “reciprocal tariffs” were expanded to virtually all U.S. trading partners. This was the first time since its creation in 1977 that the IEEPA has been used by a president to implement tariffs.

Following intense disputes with China, these tariffs eventually rose to 145%, a cost that would put the family-owned corporations Learning Resources, Inc. and hand2mind, Inc. out of business. They sued in the U.S. District Court of Washington D.C. arguing that the IEEPA does not authorize the President to levy tariffs, a form of tax, of this magnitude citing Article I, Section 8 of the Constitution that vests in Congress the sole power to tax.

The Decision

In a 6–3 decision authored by Chief Justice Roberts, the Supreme Court decided in favor of Learning Resources, Inc. et al. Central to Roberts’ opinion is the Major Questions Doctrine and lack of precedent in this use of the IEEPA. For the doctrine to apply, there must exist a claim of authority over an issue of “vast economic and political significance,” and when this threshold is met, the agency must be able to identify clear and well-defined authorization by Congress.

In this scenario, the President could not. Through the IEEPA, Congress gives the executive the power to “regulate commerce,” naming several specific permitted actions that can be taken by the president; none of which include tariffs. With other functions being so well defined, the Court reasoned that the omission of this power points to its intentional exclusion. Furthermore, in the 50 years of presidential use of the IEEPA, no other president has interpreted this law to allow tariffs, reinforcing a lack of authorization.

The Major Questions Doctrine

Being so central to a case affecting millions of Americans, what is the Major Questions Doctrine? While the concept has existed for decades, the term was not formally recognized by the Supreme Court until West Virginia v. Environmental Protection Agency, 597 U.S. 697 (2022), and its significance has continued to grow.

Today, there are three primary interpretations of the doctrine: the Clear Statement Approach, the Contextual Approach, and the Hybrid Approach.

Under the Clear Statement Approach, Justice Gorsuch argues that courts must identify explicit statutory language authorizing agency action before upholding broad delegations of power. This creates a firm standard requiring Congress to act with precision and intent, often limiting executive authority.

In contrast, Justice Barrett’s Contextual Approach emphasizes textualism and common-sense interpretation. In Biden v. Nebraska, 600 U.S. 477 (2023), she illustrated this with an analogy: giving a babysitter a credit card to “make sure the kids have fun” does not justify extravagant spending unless the surrounding context supports such authority. Barrett argues that context and reasonable inference should guide interpretation, criticizing the Clear Statement Approach for giving too much discretion to judges.

Chief Justice Roberts adopts a Hybrid Approach, incorporating elements of both. Rather than committing to one framework, he applies the doctrine flexibly in extraordinary cases. This ambiguity allows the Court discretion while maintaining broader consensus across ideological lines.

Conclusion

The decision in Learning Resources, Inc. v. Trump (2026) marks a significant limitation on executive power, but key questions remain unresolved. The Major Questions Doctrine itself lacks a clear, consistent definition and remains open to future interpretation.

Additionally, the ruling only prohibits tariffs under the IEEPA, leaving open the possibility of alternative statutory mechanisms. The economic consequences also remain uncertain. As of December 2025, the U.S. Treasury had collected over $133 billion from these tariffs. Although deemed unconstitutional, the Court did not determine whether or how these funds will be returned, acknowledging that the process “is likely to be a mess.”

Bibliography

  • International Emergency Economic Powers Act, 50 U.S.C. §§ 1701–1708.
  • Austin Piatt & Damonta Morgan, The Three Major Questions Doctrines, 2023 Wis. L. Rev. 1 (2024).
  • Learning Resources, Inc. v. Trump, 607 U.S. ___, Nos. 24-1287 & 25-250 (Feb. 20, 2026).
  • U.S. Const. art. I, § 8, cls. 1 & 3.
  • Biden v. Nebraska, 600 U.S. 477 (2023).
  • West Virginia v. EPA, 597 U.S. 697 (2022).
  • Kate R. Bowers, The Major Questions Doctrine, Cong. Rsch. Serv., IF12077 (2026).