International Trading Company v. United States’s Empirical Analysis
281 F.3d 1268 · 2002
Citation profile
20 federal appellate · 4 state decisions
How this case has been cited
Cited by 124 later decisions (26 by the Supreme Court) — most recently April 2025 · most notably Wheeler v. Comm'r (2006), United States v. Escalante-Reyes (2012)
20 federal appellate · 4 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc. · United States v. Mead Corp. · St. Paul Fire & Marine Insurance v. United States · 642 F. Supp. 1187 - American Permac, Inc. v. United States
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 124 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[e]xcept as provided in [19 U.S.C. 1675(a)(3) ], when a suspension required by statute or court order is removed, the Customs Service shall liquidate the entry, unless liquidation is extended under subsection (b) of this section, within 6 months after receiving notice of the removal from the Department of Commerce. Any entry not liquidated by the Customs Service within 6 months after receiving such notice shall be treated as having been liquidated at the rate of duty, value, quantity, and amount of duty asserted at the time of entry by the importer of record.”
6 later decisions quote this exact passage · from the majority“[T]he date of publication provides an unambiguous and public starting point for the six-month liquidation period, and it does not give the government the ability to postpone indefinitely the removal of suspension of liquidation (and thus the date by which liquidation must be completed) as would be the case if the six-month liquidation period did not begin to run until Commerce sent a message to Customs advising of the removal of suspension of liquidation. Beyond that, treating the date of notification as separate from the date of publication could lead to messy factual disputes about when Customs actually received notice of the removal of the suspension of liquidation. As in this case, the courts would be required to referee debates about what kind of communication from Commerce relating to the announcement of the final results constituted a qualifying “notice” of the removal of suspension.”
5 later decisions quote this exact passage · from the majority“Before section 1504 was enacted, there was no statutory restriction on the length of time Customs could take to liquidate an entry. St. Paul Fire & Marine Ins. Co. v. United States, 6 F.3d 763, 767 (Fed.Cir. 1993). "Customs could delay liquidation as long as it pleased, with or without giving notice.” Int’l Cargo & Surety Ins. Co. v. United States, 779 F.Supp. 174, 177 (CIT 1991). In 1978, Congress enacted section 1504 to impose a four-year time limit for liquidation. The primary purpose of section 1504 was to "increase certainty in the customs process for importers, surety companies, and other third parties with a potential liability relating to a customs transaction.” Dal-Tile Corp. v. United States, 829 F.Supp. 394, 399 (CIT 1993) (internal quotations and citation omitted).”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.