American Customs Brokers Co. v. United States Customs Service

637 F. Supp. 218, 10 Ct. Int'l Trade 385, 10 C.I.T. 385, 1986 Ct. Intl. Trade LEXIS 1227
CourtUnited States Court of International Trade
DecidedMay 27, 1986
DocketCourt 86-04-00526
StatusPublished
Cited by10 cases

This text of 637 F. Supp. 218 (American Customs Brokers Co. v. United States Customs Service) is published on Counsel Stack Legal Research, covering United States Court of International Trade primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Customs Brokers Co. v. United States Customs Service, 637 F. Supp. 218, 10 Ct. Int'l Trade 385, 10 C.I.T. 385, 1986 Ct. Intl. Trade LEXIS 1227 (cit 1986).

Opinion

OPINION AND ORDER

RESTANI, Judge:

Plaintiff American Customs Brokers (ACB) is a licensed customhouse broker. As such, it enters goods as an agent of the importer of record or as the importer of record itself. When immediate delivery is involved, it exercises the immediate delivery privileges of its principal, the importer of record, in the first instance, and it exercises its own immediate delivery privileges in the latter case. 1 In late March, the United States Customs Service (Customs) discontinued plaintiffs immediate delivery privileges for an indefinite period, ostensibly because ACB listed erroneous social security or tax identification numbers on entry papers of a number of automobiles which were entered under bond pending installation of emissions control and automobile safety equipment meeting U.S. standards. 2 In addition, ACB was denied the right to act as a broker on any transaction involving the immediate delivery privileges of any other party acting as importer of record. Approximately one month after the discontinuance of the privileges, plaintiff filed a complaint seeking a temporary restraining order, and preliminary and permanent injunctions reinstating these privileges. The court issued a temporary restraining order on April 30, 1986, barring Customs from continued implementation of the revocation pending disposition of plaintiffs motion for a preliminary injunction, now before the court.

*220 The parties do not dispute the following facts underlying the action. In May of 1985, Customs seized two vehicles entered by ACB because the entry identification numbers were not social security numbers issued by the Social Security Administration. 3 Shortly thereafter, ACB provided the correct numbers and the vehicles were released. On November 27, 1985, ACB received a letter from Customs informing it that an audit of the firm would be conducted by Customs on December 12, 1985, to determine compliance with customs regulations. Upon completion of the audit, Customs concluded that of the 242 entries into the Los Angeles, California district that contained erroneous social security numbers in identifying importers of record, 102 were entries in which ACB had acted as broker. 4 In response to this finding, Customs decided to take the action challenged here. On March 28, 1986, Aileen Colon, Chief Inspector of Customs at Terminal Island, orally informed representatives of ACB of Customs’ decision. Subsequently, plaintiff's representatives had several discussions with Customs in an attempt to identify reasons for the discontinuance and to persuade Customs to reinstate the privileges. When these discussions proved unsatisfactory to plaintiff, plaintiff filed suit in this court.

Plaintiff contends that, at a minimum, it was entitled to written notice and an opportunity to respond before Customs could discontinue its privileges. It claims that the procedures followed by Customs deprived it of its right to procedural due process, rendering the discontinuance invalid. Thus, plaintiff seeks to have its privileges reinstated until the matter can be resolved on the merits.

The Court of Appeals for the Federal Circuit has defined the criteria for issuance of a preliminary injunction as follows:

(1) the threat of immediate irreparable harm;
(2) the likelihood of success on the merits;
(3) whether the public interest would be better served by issuing rather than by denying the injunction; and
(4) whether the balance of hardships on the parties favors issuing the injunction.

Zenith Radio Corp. v. United States, 710 F.2d 806, 809 (Fed.Cir.1983); S.J. Stile Associates, Ltd. v. Snyder, 68 CCPA 27, 30, 646 F.2d 522, 525 (Fed.Cir.1981); Azurin v. United States, 10 CIT —, 632 F.Supp. 30, 31-32 (1986).

To demonstrate irreparable injury, plaintiff must prove that unless the injunction is awarded, some harm will result to it that cannot be reasonably redressed in a court of law. National Juice Products Association v. United States, 10 CIT —, 628 F.Supp. 978, 984 (1986) (citing Manufacture de Machines du Haut Rhin v. Von Raab, 6 CIT 60, 569 F.Supp. 877, 881-82 (1983)). In making this determination, the court must focus on the immediacy of the harm and the adequacy of future corrective relief. S.J. Stile, 63 CCPA at 30, 646 F.2d at 525 (“A presently existing, actual threat must be shown.”); Azurin, 10 CIT at —, 632 F.Supp. at 32 (“An injury is irreparable if it cannot be undone through monetary remedies.”); National Juice Products, 10 CIT at —, 628 F.Supp. at 984 (the magnitude of the injury is not critical, rather the immediacy of the injury and the adequacy of the future relief).

It does not appear to be disputed here that immediate delivery privileges are an *221 important part of plaintiff’s operations. In addition, plaintiff has submitted affidavits (and has produced detailed testimony) that demonstrate that it has lost existing business accounts and has had to forego business opportunities due to the revocation of its immediate delivery privileges. There appears to be evidence of substantial harm to business good will, business reputation and a significant loss of new business. See Lois Jeans & Jackets, U.S.A., Inc. v. United States, 5 CIT 238, 242, 566 F.Supp. 1523, 1527 (1983) (Customs order to redeliver goods enjoined where loss of past and future sales and injury to reputation as a reliable supplier constituted irreparable injury); cf. Mutual of Omaha Insurance Co. v. Novak, 775 F.2d 247, 249 (8th Cir.1985) (court affirmed finding of irreparable injury based on injury to business reputation and good will arising from alleged trademark infringement). It is very difficult to accurately access these types of damage for purposes of monetary recovery. In addition, it is doubtful that the defendant would be subject to suit for the actions alleged here. See 28 U.S.C. § 2680 (1982). “The possibility that adequate compensatory or other corrective relief will be available at a later date ... weighs heavily against a claim of irreparable harm.” National Com Growers Association v. Baker, 9 CIT —, 623 F.Supp. 1262,1275 (1985) (quoting Sampson v. Murray, 415 U.S. 61, 90, 94 S.Ct. 937, 953, 39 L.Ed.2d 166 (1974), quoting Virginia Petroleum Jobbers Association v. FPC, 259 F.2d 921, 925 (D.C.Cir.1958)).

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Cite This Page — Counsel Stack

Bluebook (online)
637 F. Supp. 218, 10 Ct. Int'l Trade 385, 10 C.I.T. 385, 1986 Ct. Intl. Trade LEXIS 1227, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-customs-brokers-co-v-united-states-customs-service-cit-1986.