Avenues in Leather, Inc. v. United States

178 F.3d 1241 (1999)

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Avenues in Leather, Inc. v. United States

United States Court of Appeals for the Federal Circuit
178 F.3d 1241 (1999)

Facts

Avenues in Leather, Inc. (Avenues) imported into the United States leather folios that were used to store, organize, and carry papers and stationery items. The folios included a leather carrying handle. The United States Customs Service (customs) classified the folios under subheading 4202.11.00 of the Harmonized Tariff Schedule of the United States (HTSUS), which covered suitcases, briefcases, school satchels, and similar containers with an outer surface of leather. Avenues challenged the classification, arguing that the folios should have been classified under subheading 4820.10.20, which included registers, diaries, notebooks, letter and memorandum pads, and similar articles. Applying the rule of ejusdem generis, the United States Court of International Trade upheld customs’ classification, holding that there was a physical similarity between the folios and the items listed under heading 4202 and that the folios’ primary purposes of organization, storage, and carrying were consistent with those of heading 4202 exemplars. Avenues appealed, arguing that the folios should have been classified under heading 4820 due to the organizational-aid and time-management purposes shared with that heading’s exemplars.

Rule of Law

Issue

Holding and Reasoning (Clevenger, J.)

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