United States v. Franco Tire Distrib., Inc.

CourtUnited States Court of International Trade
DecidedJune 17, 2026
Docket24-00161
StatusPublished

This text of United States v. Franco Tire Distrib., Inc. (United States v. Franco Tire Distrib., Inc.) 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
United States v. Franco Tire Distrib., Inc., (cit 2026).

Opinion

Slip Op. 26-66

UNITED STATES COURT OF INTERNATIONAL TRADE ____________________________________ : THE UNITED STATES, : : Plaintiff, : : Before: Richard K. Eaton, Judge v. : : Court No. 24-00161 FRANCO TIRE DISTRIBUTION, INC., : : Defendant. : ____________________________________:

OPINION

[Granting Plaintiff the United States’ Motion for Default Judgment.]

Dated: June 17, 2026

Isabelle Aubrun, Trial Attorney, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, D.C., for Plaintiff the United States. With her on the brief were Brett A. Shumate, Assistant Attorney General, Patricia M. McCarthy, Director, and Reginald T. Blades, Jr., Assistant Director. Of Counsel was Brian Dublon, Office of the Associate Chief Counsel, U.S. Customs and Border Protection.

Eaton, Judge: This is a civil penalty case brought by Plaintiff the United States

(“Government”), on behalf of U.S. Customs and Border Protection (“Customs”), against

Defendant Franco Tire Distribution, Inc. (“Franco”), a U.S. importer, for alleged negligent

violations of 19 U.S.C. § 1592. Compl. ¶ 1, ECF No. 4. Jurisdiction is found under 28 U.S.C.

§ 1582(1).

Before the court is the Government’s motion for default judgment. Pl.’s Mot. for Entry of

Default J., ECF No. 26 (“Pl.’s Br.”). For the following reasons, the court grants the motion and

enters judgment against Franco in the amount of $55,882.98, plus interest as provided by law. Id.

at 8-9. Court No. 24-00161 Page 2

BACKGROUND I. Civil Penalties Under Section 1592

Title 19 U.S.C. § 1592 penalizes material, false statements or material omissions in

connection with the importation of merchandise into the United States:

Without regard to whether the United States is or may be deprived of all or a portion of any lawful duty, tax, or fee thereby, no person, by fraud, gross negligence, or negligence—

(A) may enter, introduce, or attempt to enter or introduce any merchandise into the commerce of the United States by means of—

(i) any document or electronically transmitted data or information, written or oral statement, or act which is material and false, or

(ii) any omission which is material, or

(B) may aid or abet any other person to violate subparagraph (A).

19 U.S.C. § 1592(a)(1). “There is no violation if the falsity or omission is due solely to clerical

error or mistake of fact, unless the error or mistake is part of a pattern of negligent conduct.”

19 C.F.R. pt 171, app. B(A). “A document, statement, act, or omission is material if it has the

natural tendency to influence or is capable of influencing agency action including, but not limited

to a Customs action regarding . . . determination of an importer’s liability for duty

(including . . . antidumping, and/or countervailing duty).” Id. app. B(B).

The statute establishes the maximum penalties for violations of section 1592(a). Where

Customs determines that a violation has occurred due to negligence, as the Government alleges

happened here, the statute limits the civil penalty to “an amount not to exceed . . . the lesser

of . . . the domestic value of the merchandise, or . . . two times the lawful duties, taxes, and fees of

which the United States is or may be deprived . . . .” 19 U.S.C. § 1592(c)(3).

Negligence, in the import context, means the failure of an importer of record, or its agent,

to exercise reasonable care when, for example, completing entry paperwork with the information Court No. 24-00161 Page 3

necessary to allow Customs to “properly assess duties on the merchandise.” 1 19 U.S.C. § 1484(a)

(providing that an “importer of record” or its agent “shall . . . us[e] reasonable care” when entering

merchandise and completing an entry summary, “by filing with the Customs Service the declared

value, classification and rate of duty applicable to the merchandise,” so that Customs can, among

other things, “properly assess duties on the merchandise”).

In a penalty action based on the alleged negligent violation of section 1592, the

Government “shall have the burden of proof to establish the act or omission constituting the

violation.” 19 U.S.C. § 1592(e)(4). Then, the burden shifts to the defendant to demonstrate a lack

of negligence. United States v. Ford Motor Co., 463 F.3d 1267, 1279 (Fed. Cir. 2006) (“Statutory

negligence under § 1592, unlike common-law negligence, shifts the burden of persuasion to the

defendant to demonstrate lack of negligence.” (citing 19 U.S.C. § 1592(e)(4)). “That is, Customs

has the burden merely to show that a materially false statement or omission occurred; once it has

done so, the defendant must affirmatively demonstrate that it exercised reasonable care under the

circumstances.” Id.

1 According to Customs’ regulations:

A violation [of section 1592] is determined to be negligent if it results from an act or acts (of commission or omission) done through either the failure to exercise the degree of reasonable care and competence expected from a person in the same circumstances either: (a) in ascertaining the facts or in drawing inferences therefrom, in ascertaining the offender’s obligations under the statute; or (b) in communicating information in a manner so that it may be understood by the recipient. As a general rule, a violation is negligent if it results from failure to exercise reasonable care and competence: (a) to ensure that statements made and information provided in connection with the importation of merchandise are complete and accurate; or (b) to perform any material act required by statute or regulation.

19 C.F.R. pt 171, app. B(C)(1). Court No. 24-00161 Page 4

II. The Government’s Civil Penalty Claim Against Franco

By its complaint, the Government alleges that Franco negligently omitted material

information when completing entry summaries for two entries of truck or bus tires from the

People’s Republic of China (“China”). Specifically, Franco omitted from the summaries the

antidumping case number (A-570-040-000) and countervailing case number (C-570-041-000) that

would have indicated to Customs that its entries of tires were subject to antidumping and

countervailing duty orders. 2 As a result of these omissions, Franco failed to pay the estimated

antidumping and countervailing duties on those entries at the time of importation. Compl. ¶¶ 31-37.

Following Customs’ discovery of the omissions and its rejection of the entries, Franco

corrected the entry summaries with the required case information and paid the amount of

antidumping and countervailing duties owed, i.e., $27,941.49. Id. ¶ 25. Franco did not, however,

pay the penalty demanded by Customs, which was equal to two times that amount, or $55,882.98.

Id. ¶ 26.

The Government timely commenced this lawsuit.

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