United States v. Yoshida International, Inc.

526 F.2d 560, 63 C.C.P.A. 15
CourtCourt of Customs and Patent Appeals
DecidedNovember 6, 1975
DocketNo. 75-6 C.A.D. 1160
StatusPublished
Cited by65 cases

This text of 526 F.2d 560 (United States v. Yoshida International, Inc.) is published on Counsel Stack Legal Research, covering Court of Customs and Patent Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Yoshida International, Inc., 526 F.2d 560, 63 C.C.P.A. 15 (ccpa 1975).

Opinion

Markey, Chief Judge.

This is an appeal from a judgment of the Customs Court, 73 Cust. Ct. 1, C.D. 4550, 378 F. Supp. 1155 (1974), granting Yoshida’s motion for summary judgment, and declaring an import duty surcharge invalid. Presidential Proclamation 4074, because it imposed the sur[17]*17charge, was held to have been beyond the President’s delegated powers. The court stated that a delegation of sufficient breadth to encompass the proclamation would have been unconstitutional. We reverse.

FACTS

Yoshida’s merchandise (zippers) was imported from Japan and entered the port of New York on August 17, 25, and 26, 1971. The government levied, in addition to the standard duty under TSUS item 745.72, an import duty surcharge of 10% in accordance with item 948.00, which was added to the TSUS by Presidential Proclamation 4074.1 Yoshida challenges only the validity of Proclamation 4074.

Amicus

American Importers Association, Inc., filed a brief amicus curiae seeking, in the event of an affirmance, a declaration that the liquidations herein were null and void and the protests premature, the effect of which would be to remove barriers to a refund of amounts exacted by the surcharge. The government filed an opposing brief. The judgment below being reversed, the requests of amicus must be dismissed as moot.

President’s Actions

During the summer of 1971, the United States was faced with an economic crisis. The nation suffered under an exceptionally severe and worsening balance of payments deficit. The gold reserve backing of the U.S. dollar had dropped from $17.8 billion in 1960 to less than $10.4 billion in June of 1971,2 reflecting a growing lack of confidence in the U.S. dollar abroad. Foreign exchange rates were being controlled by some of our major trading partners in such a way as to overvalue the U.S. dollar. That action, by stimulating U.S. imports and restraining U.S. exports, contributed substantially to the balance of payments deficit.3 As one step in a program designed to meet the economic crisis,4 the President issued Proclamation 4074, which in relevant part stated:

[18]*18WHEREAS, there has been a prolonged decline in the international monetary reserves of the United States, and our trade and international competitive position is seriously threatened and, as a result, our continued ability to assure our security could be impaired;
WHEREAS, the balance of payments position of the United States requires the imposition of a surcharge on dutiable imports;
* * * *
A. I hereby declare a national emergency during which I call upon the public and private sector to make the efforts necessary to strengthen the international economic position of the United States.
B. (1) I hereby terminate in part for such period as may be necessary and modify prior Presidential Proclamations which carry out trade agreements insofar as such proclamations are inconsistent with, or proclaim duties different from, those made effective pursuant to the terms of this Proclamation.
(2) Such proclamations are suspended only insofar as is required to assess a surcharge in the form of a supplemental duty amounting to 10 percent ad valorem. Such supplemental duty shall be imposed on all dutiable articles * * * provided, however, that if the imposition of an additional duty of 10 percent ad valorem would cause the total duty or charge payable to exceed the total duty or charge payable at the rate prescribed in column 2 of the Tariff Schedules of the United States, then the column 2 rate shall apply.

To implement the above language, Proclamation 4074 established the following item 948.00 of subpart C, part 2, of TSUS Appendix:

Rates of duty

Item Article 1 2

The referenced headnote 3 reads as follows:

3. Limitation on additional duties — The additional 10 percent rate of duty specified in rate of duty column numbered 1 of item 948.00 shall in no event exceed that rate which, when added to the column numbered 1 rate imposed on the imported article under the appropriate item in schedules 1 through 7 of these schedules, would result in an aggregated rate in excess of the rate provided for such article in rate of duty column numbered 2.

The President’s authority for proclaiming the surcharge was stated in Proclamation 4074 to be:

WHEREAS, pursuant to the authority vested in him by the Constitution and the statutes, including, but not limited to, the Tariff Act of 1930, as amended (hereinafter referred to as “the Tariff Act”), and the Trade Expansion Act of 1962 (hereinafter [19]*19referred to as “the TEA”), the President entered into, and proclaimed tariff rates under, trade agreements with foreign countries;
WHEREAS, under the Tariff Act, the TEA and other provisions of law, the President may, at any time, modify or terminate, in whole or in part, any proclamation under his authority; * * *.

Importers of products subject to the surcharge sought and obtained permission from the Cost of Living Council to pass the surcharge through to customers as part of the price of the imported articles.5

Within less than five months following imposition of the surcharge, a multilateral agreement (The “Smithsonian Agreement” of December 18, 1971) among the major industrial nations was reached6 which, inter alia, gave promise of ending the overvaluation of the U.S. dollar in relation to other major currencies. On December 20, 1971, the import duty surcharge was terminated. (Presidential Proclamation 4098, 36 Fed. Reg. 24201 (1971).)

Customs Court

The main opinion below7 dealt extensively with the President’s termination and emergency powers, finding that neither encompassed the tariff surcharge promulgated in Proclamation 4074.

The President’s termination power, as expressed in the Tariff Act of 1930, as amended (Tariff Act) and the Trade Expansion Act of 1962 (TEA), was construed as follows:

We conclude that the authority granted by statute to “terminate, in whole or in part, any proclamation” does not include the power to determine and fix unilaterally a rate of duty which has not been previously legally established. On the contrary, the “termination” authority, as statutorily granted, merely provides the President with a mechanical procedure of supplanting or replacing existing rates with rates which have been established by prior proclamations or by statute. Relevant thereto is United States v. American Bitumuls & Asphalt Co., 44 CCPA199, C.A.D. 661, 246 F. 2d 270 (1957), cert. denied, 355 U.S. 883 (1957).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Learning Resources, Inc. v. Trump
District of Columbia, 2025
V.O.S. Selections, Inc. v. Trump
2025 CIT 66 (Court of International Trade, 2025)
Amdor v. Grisham
New Mexico Supreme Court, 2025
American Institute for Int'l Steel, Inc. v. United States
376 F. Supp. 3d 1335 (Court of International Trade, 2019)
Odebrecht Construction, Inc. v. Prasad
876 F. Supp. 2d 1305 (S.D. Florida, 2012)
Canadian Lumber Trade Alliance v. United States
425 F. Supp. 2d 1321 (Court of International Trade, 2006)
Thomson Consumer Electronics, Inc. v. United States
62 F. Supp. 2d 1182 (Court of International Trade, 1999)
Bernstein v. United States Department of State
974 F. Supp. 1288 (N.D. California, 1997)
Libas, Ltd. v. United States
20 Ct. Int'l Trade 1215 (Court of International Trade, 1996)
United States v. Goldberger & Dubin, P.C.
935 F.2d 501 (Second Circuit, 1991)
Stinson Canning Co., Inc. v. Mosbacher
731 F. Supp. 32 (D. Maine, 1990)
Arjay Associates, Inc. v. Bush
891 F.2d 894 (Federal Circuit, 1989)
North American Foreign Trading Corp. v. United States
10 Ct. Int'l Trade 480 (Court of International Trade, 1986)
Sunburst Farms, Inc. v. United States
9 Ct. Int'l Trade 512 (Court of International Trade, 1985)
Sacilor, Acieries Et Laminoirs De Lorraine v. United States
613 F. Supp. 364 (Court of International Trade, 1985)

Cite This Page — Counsel Stack

Bluebook (online)
526 F.2d 560, 63 C.C.P.A. 15, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-yoshida-international-inc-ccpa-1975.