When the Supreme Court issued its landmark decision in Learning Resources, Inc. v. Trump this past February, one had to sift through seven different judicial opinions spanning 170 pages to understand that the court invalidated the sweeping tariffs imposed by the Trump administration under the International Emergency Economic Powers Act. Still, that decision left many issues unresolved, the most important of which was how the administration was supposed to refund billions in illegal tariffs to those who paid them.
Instead of answering that important question, it returned the case to the relatively obscure Court of International Trade, a body created by Congress in 1980 to help resolve issues affecting, as its name suggests, international trade.
While one might think this was a recipe for mischief, an unlikely hero has arisen, Judge Richard Eaton of that court, who appears to be holding the administration’s feet to the fire and does not appear like he is about to tolerate many shenanigans should the administration seek to drag those feet in an effort to evade the law.
While Trump administration officials may have believed they could tie the case up in the courts for months, even years, Eaton has different thoughts about how, and when, to refund those who paid these illegal tariffs, and he has laid it all out in two opinions spanning no more than six pages of text combined.
At a time when lawyers and judges gravitate toward complex reasoning, obscuring jargon and legal briefs and opinions that seemingly go on forever, Eaton has taught a masterclass in simple, concise and clear language. What this straightforward approach has done is not only made it patently clear what the administration’s legal obligations are, he has left little wiggle room for the administration to avoid reparations.
Eaton, a 77-year-old jurist who once served as a village justice in rural upstate New York, has taken the reins of this sprawling, high-stakes legal battle. In the case of Atmus Filtration, Inc. v. United States, the plaintiff is seeking an immediate refund of the payments it made under the illegal tariff scheme. Eaton’s first opinion in the case is a model of judicial brevity and clarity. And he has also shown no patience for bureaucratic stonewalling.
The first decision was issued on March 4, 2026. Importers across the country may have been bracing for a convoluted, multiyear slog to get their money back, but Eaton quickly eased those fears. In a simple, three-page order, he directed Customs and Border Protection to refund the illegal tariffs paid by American companies.
At a time when lawyers and judges gravitate toward complex reasoning, obscuring jargon and legal briefs and opinions that seemingly go on forever, Eaton has taught a masterclass in simple, concise and clear language.
But that’s not all he did. He also brushed aside the government’s possible procedural defenses. Despite the Supreme Court’s recent holding in Trump v. CASA, Inc. — that frowned upon so-called “universal” or nationwide injunctions — in just a few plainspoken sentences, Eaton dismantled this hurdle. He pointed out that Congress provided the CIT with “national geographic jurisdiction” and “exclusive subject matter jurisdiction” over these very claims. Because he is the only judge hearing these refund cases, there is no risk of conflicting decisions from other courts.
He also extended the benefit of the Supreme Court’s ruling to all importers whose entries were subject to the illegal tariffs, declaring that finding otherwise would “thwart the efficient administration of justice.” There was no bloated dicta. No attempt at soaring or purple prose. No contortionist logic to reach a preferred decision or to justify refraining from reaching a decision. Just clear directives that have paved the way for nationwide relief.
Naturally, the government balked. On March 6, a representative of the CBP, the entity responsible for collecting, and now refunding, the tariffs, submitted a sworn statement to Judge Eaton that the agency could not comply immediately with the court’s order to refund those American companies that paid the illegal tariffs. Instead, CBP is now saying it is going to create a mechanism for facilitating refunds of the tariffs, but that it needs 45 days to implement the system.
Rather than letting the government use this excuse to indefinitely stall, Eaton issued his second order later that same day.
If his first order was brief, his March 6 order was a paragon of judicial economy — weighing in at just two pages. Acknowledging that CBP has proposed the creation of an automated process, he temporarily suspended the demand for immediate compliance but kept the agency on an incredibly tight leash. He bluntly laid out the stakes to justify his speed: The $165 billion in collected duties is currently accruing approximately $650 million in interest every single month. If the entries are not liquidated by the end of the year, he explained, American taxpayers will be on the hook for an estimated $10 billion in interest alone. With that staggering figure stalking the administration’s processes, Eaton accepted the complexity of the task at hand but also ordered the government to file a progress report by March 12, promising to keep tabs on the CBP, which he has done. That March 12 briefing has come and gone, and Eaton is expecting regular briefings from the government to ensure it is making progress, including receiving one such briefing Thursday. When it too often seems like the legal system is paralyzed by procedural gamesmanship and judicial opinions frequently span hundreds of pages, and sometimes constitute tales of sound and fury signifying little, Eaton’s approach is a breath of fresh air. His rulings demonstrate that the most effective jurisprudence is often the most direct. He saw a problem — billions of dollars in illegally collected taxes and an administration reluctant to return them — and he used his court’s unique jurisdictional power to solve it. He didn’t write for the history books, even as he made history; he wrote to get American businesses their money back and to protect American taxpayers from footing a multibillion-dollar interest bill. The Constitution requires that tariffs be lawful, and the Supreme Court has confirmed that these were not. But rights without remedies are meaningless. Thanks to the brevity, clarity and undeniable courage of a seasoned judge in lower Manhattan, who no doubt has seen his share of litigant mischief in his court for decades, the rule of law is being enforced in as straightforward and efficient a manner as possible. In a world where the courts must serve as a significant check on abuses of power, particularly executive power, we need more judges like Eaton: those with the courage, and the willingness, to, in the words of Chief Justice John Marshall from over 200 years ago, “say what the law is” and to do so in a concise, fair, clear and accessible manner.
Ray Brescia
Ray Brescia is a professor of law at Albany Law School and author of the book “The Private Is Political: Identity and Democracy in the Age of Surveillance Capitalism.” 
