Houston Shutters LLC v. United States

2026 CIT 07
CourtUnited States Court of International Trade
DecidedJanuary 29, 2026
Docket24-00193
StatusPublished

This text of 2026 CIT 07 (Houston Shutters LLC v. United States) 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
Houston Shutters LLC v. United States, 2026 CIT 07 (cit 2026).

Opinion

Slip Op. 26-7

UNITED STATES COURT OF INTERNATIONAL TRADE

HOUSTON SHUTTERS LLC,

Plaintiff, Before: Leo M. Gordon, Judge v. Court No. 24-00193 UNITED STATES,

Defendant.

OPINION

[Denying Defendant’s motion to dismiss under USCIT Rule 12(b)(1).]

Dated: January 29, 2026

Jordan C. Kahn, Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt of New York, N.Y., argued for Plaintiff Houston Shutters LLC. With him on the brief was Alan R. Klestadt.

Emma E. Bond, Senior Trial Attorney, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, D.C., argued for Defendant United States. With her on the briefs were Brett A. Shumate, Assistant Attorney General, Patricia M. McCarthy, Director, Claudia Burke, Deputy Director, and Brendan D. Jordan, Trial Attorney. Of counsel was Ruslan Klafehn, Attorney, Office of the Chief Counsel for Trade Enforcement and Compliance, U.S. Department of Commerce, of Washington, D.C.

Gordon, Judge: This action involves Plaintiff Houston Shutters LLC’s challenge to

the U.S. Department of Commerce’s (“Commerce”) decision not to initiate a changed

circumstances review (“CCR”) 1 with respect to whether wood shutter components were

1 “A changed circumstances review is a statutorily required administrative process whereby Commerce, upon request, must review a final affirmative determination resulting in an antidumping duty order if an interested party has demonstrated the existence of changed circumstances sufficient to warrant review. Trs. in Bankr. of N. Am. Rubber (footnote continued) Court No. 24-00193 Page 2

within the scope of the investigation covering millwork products from the People’s

Republic of China. Plaintiff brought its challenge in the form of two separate actions

seeking the same relief on the same facts, albeit under different jurisdictional provisions.

Compare Compl., ECF No. 2 (action under 28 U.S.C. § 1581(i)), with Compl., Ct.

No. 24-00175, ECF No. 8 (action under § 1581(c)).

Before the court is Defendant’s motion to dismiss this action for lack of subject

matter jurisdiction pursuant to USCIT Rule 12(b)(1). See Def.’s Mot. to Dismiss, ECF

No. 14 (“Def.’s Mot.”); see also Pl.’s Resp., ECF No. 15; Def.’s Reply, ECF No. 16; Oral

Arg., ECF No. 27 (May 29, 2025); Def.’s Supp. Br., ECF No. 29 (“Def.’s Supp. Br.”); Pl.’s

Supp. Resp., ECF No. 30 (“Pl.’s Supp. Resp.”). For the reasons set forth below, the court

will deny Defendant’s motion to dismiss this action.

I. Standard of Review

The claimant carries “the burden of demonstrating that jurisdiction exists.”

Techsnabexport, Ltd. v. United States, 16 CIT 420, 422, 795 F. Supp. 428, 432 (1992)

(citing McNutt v. Gen. Motors Acceptance Corp., 298 U.S. 178, 189 (1936)). If the court

determines at any time that it lacks subject matter jurisdiction, the court must dismiss the

action. USCIT Rule 12(h)(3). In deciding a USCIT Rule 12(b)(1) motion to dismiss that

does not challenge the factual basis for the complainant’s allegations, the court assumes

Thread Co. v. United States, 30 CIT 1537, 1538 n.3, 464 F. Supp. 2d 1350, 1352 n.3 (2006), aff’d in part, rev’d in part, 593 F.3d 1346 (Fed. Cir. 2010) (“Trustees II”) (citing 19 U.S.C. § 1675(b)(1)). Court No. 24-00193 Page 3

all factual allegations to be true and draws all reasonable inferences in the claimant’s

favor. Henke v. United States, 60 F.3d 795, 797 (Fed. Cir. 1995).

However, where the “motion challenges a complaint’s allegations of jurisdiction,

the factual allegations in the complaint are not controlling and only uncontroverted factual

allegations are accepted as true.” Shoshone Indian Tribe of Wind River Rsrv., Wyo. v.

United States, 672 F.3d 1021, 1030 (Fed. Cir. 2012). To “resolv[e] these disputed

predicate jurisdictional facts, a court is not restricted to the face of the pleadings, but may

review evidence extrinsic to the pleadings.” Id. (internal quotation marks and citation

omitted). Since the Government disputes the factual underpinnings of jurisdiction, the

court may consider evidence outside of the complaint. Shoshone Indian Tribe, 672 F.3d

at 1030.

II. Discussion

Defendant’s argument hinges on the proposition that the court can determine the

“true nature” of Plaintiff’s action. Problematically, Defendant fails to explain how the court

is to apply this standard based on the factual allegations provided by Plaintiff. Rather,

Defendant generally leaves it to the court to determine which jurisdictional facts are at

issue and to dig through the administrative record, unguided. Defendant also urges the

court to confirm that Plaintiff’s alleged challenge to the denial of a CCR is spurious and

instead that Plaintiff is truly seeking to challenge Commerce’s initial scope determination.

The sum and substance of the entirety of Defendant’s argument is as follows:

Houston Shutters cannot invoke jurisdiction under subsection 1581(i) in this matter because the true nature of Houston Shutters’ action is a challenge to Commerce’s Court No. 24-00193 Page 4

determination in the underlying antidumping and countervailing duty investigations that wood shutter components are covered by the scope of the orders. Because Houston Shutters could have challenged that decision before this Court pursuant to this Court’s jurisdiction under section 1581(c), Houston Shutters is barred from pursuing a 1581(i) case instead. See 28 U.S.C. § 1581(i); 19 U.S.C. § 1516a(a)(2)(B)(i) (providing section 1581(c) jurisdiction over Commerce’s affirmative final determinations in investigations); Sunpreme[, Inc. v. United States, 892 F.3d 1186, 1191 (Fed. Cir. 2018)]. That Houston Shutters characterizes its claim as a request to initiate a CCR as opposed to a challenge to the scope set in the investigations of these proceedings is irrelevant. This is because “[a] party may not expand a court’s jurisdiction by creative pleading.” Sunpreme, 892 F.3d at 1193 (quoting [Norsk Hydro Can., Inc. v. United States, 472 F.3d 1347, 1355 (Fed. Cir. 2006)]). Instead, the Court must “look to the true nature of the action . . . in determining jurisdiction of the appeal.” Id. (quoting same). Indeed, the Federal Circuit has held multiple times that “recasting a scope dispute” as another type of challenge when the true nature of the action is a “scope dispute” does not create § 1581(i) jurisdiction. See, e.g., [TR Int’l Trading Co., Inc. v.

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Related

McNutt v. General Motors Acceptance Corp.
298 U.S. 178 (Supreme Court, 1936)
Donald A. Henke v. United States
60 F.3d 795 (Federal Circuit, 1995)
Trustees in Bankruptcy of North American Rubber Thread Co. v. United States
464 F. Supp. 2d 1350 (Court of International Trade, 2006)
Techsnabexport, Ltd. v. United States
795 F. Supp. 428 (Court of International Trade, 1992)
National Nail Corp. v. United States
335 F. Supp. 3d 1321 (Court of International Trade, 2018)
Tr International Trading v. United States
4 F.4th 1363 (Federal Circuit, 2021)
Rimco Inc. v. United States
98 F.4th 1046 (Federal Circuit, 2024)

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2026 CIT 07, Counsel Stack Legal Research, https://law.counselstack.com/opinion/houston-shutters-llc-v-united-states-cit-2026.