Government lawyers filed an opening brief on Monday with the U.S. Court of Appeals for the Federal Circuit, challenging a Court of International Trade (CIT) judge's February order. The CIT judge had directed the U.S. Customs and Border Patrol (CBP) to issue refunds to all companies that paid tariffs deemed illegal, even those that did not file a lawsuit. The government argues this constitutes an overreach of authority, citing a June 2025 Supreme Court decision that limited the use of universal injunctions. CBP has already processed and certified $100 billion in refunds, but the appeal concerns companies for whom the administrative refund process is no longer available.