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Simplified, et al. v. Trump, et al.

Representing  Simplified, a Pensacola-based company owned by entrepreneur Emily Ley, and several other Florida companies, NCLA challenges President Trump’s attempt to rely on the International Emergency Economic Powers Act (IEEPA) to impose tariffs on imports from all U.S. trading partners. This statute authorizes specific emergency actions like imposing sanctions or freezing assets to protect the United States from foreign threats. It does not authorize the President to impose tariffs. In its nearly 50-year history, no other president—including President Trump in his first term—has ever tried to use the IEEPA to impose tariffs. This lawsuit does not contest President Trump’s declaration of opioid and trade deficit-related emergencies, but it does take issue with his decision to impose tariffs in response, without legal authority to do so.

The tariffs are harmful to Simplified, a company that improves women’s lives by selling premium planners and other home management products, and NCLA’s other clients in this case. Simplified’s business depends on importing materials from China, and it already has paid substantial tariffs to purchase goods from China that are not available here. The “emergency” tariff on goods from China will force it to make higher tariff payments, driving up its costs and thus prices for its customers, and reducing its profits.

Under art. 1, § 8 of the Constitution, Congress has sole authority to control tariffs, which it has done by passing detailed tariff statutes. The President cannot bypass those statutes by invoking “emergency” authority in another statute that does not mention tariffs. His attempt to use the IEEPA this way not only violates the law as written, but it also invites application of the Supreme Court’s Major Questions Doctrine, which tells courts not to discern policies of “vast economic and political significance” in a law without explicit congressional authorization. If the IEEPA were held to permit these tariff actions, then the statute would run afoul of the nondelegation doctrine because it lacks an “intelligible principle” to limit or guide the president’s discretion in imposing tariffs.

Emily Ley, CEO, Simplified

Andrew Morris
Senior Litigation Counsel
Mark Chenoweth
President and Chief Legal Officer
John J. Vecchione
Senior Litigation Counsel
Zhonette Brown
General Counsel and Senior Litigation Counsel
NCLA FILINGS

Memorandum of Amicus Curiae the Cato Institute in Support of Plaintiffs

May 13, 2025 | Read More

Brief of Amicus Curiae the Brennan Center for Justice in Support of Plaintiffs

May 12, 2025 | Read More

Joint Brief of Amici Curiae Former Senator and Governor George F. Allen, Professor Steven Calabresi, Attorney Joshua A. Claybourn, Former Senator and Ambassador to the United Nations John C. Danforth, Professor Richard A. Epstein, Former Senator and Secretary of Defense Charles T. Hagel, Professor and Former Dean Harold Hongju Koh, Professor Gerard N. Magliocca, Professor and Former Judge Michael W. McConnell, Former Attorney General and Judge Michael B. Mukasey, Professor Alan Sykes, Former Judge John Daniel Tinder, Former White House Counsel Peter Wallison, Former State Department Counselor and Director of the 9/11 Commission Philip Zelikow in Support of Plaintiffs

May 8, 2025 | Read More

Plaintiffs' Memorandum in Opposition to Defendants' Motion to Transfer and Unopposed Motion to Expedite

May 5, 2025 | Read More

Amended Complaint for Injunctive and Declaratory Relief

May 5, 2025 | Read More

PRESS RELEASES

NCLA Opposes Transfer of Expanded Lawsuit Against Trump Administration’s Unlawful Tariffs

May 5, 2025 | Read More

NCLA Sues to Stop Trump Admin. from Imposing Emergency Tariffs That Congress Never Authorized

April 3, 2025 | Read More

IN THE MEDIA

Trump’s tariffs are unconstitutional — we’re suing to end them

April 15, 2025

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