Len-Ron Manufacturing Co., Inc. v. United States

Len-Ron Manufacturing Co., Inc., Aramis, Inc., and Clinique Laboratories, Inc. (collectively, Len-Ron) (plaintiffs) imported cosmetics bags into the United States. These products were small, frameless, polyvinyl bags made to carry makeup. United States Customs and Border Protection (customs) (defendant) classified the bags under the Harmonized Tariff Schedule of the United States (HTSUS) under subheading 4202.92, which covered travel, sport, and similar bags, and which subjected those products to a 20 percent duty. Len-Ron filed a protest, arguing that the bags should have been classified under subheading 4202.32, which covered articles normally carried in a handbag, and which subjected those products to a lesser duty. Customs denied the protest, and Len-Ron challenged the denial before the United States Court of International Trade. There, customs argued, in the alternative, that the bags could be classified as vanity cases under subheading 4202.12. Consulting dictionaries, the court interpreted vanity case to refer to small bags used to hold cosmetics and found that the bags could be classified prima facie under 4202.12, but also under 4202.32, as vanity cases were typically carried in handbags. Applying HTSUS General Rule of Interpretation (GRI) 3, the court held that the more specific subsection 4202.12 applied to the bags. Len-Ron appealed, arguing, in part, that the court erred by failing to apply certain cannons of statutory interpretation or consult relevant drafting history.