## Facts

- Heartland By-Products, Inc., a sugar refiner, sought a Customs advance ruling in 1995 for Canadian sugar-syrup imports for further refining in the United States.
- Customs issued a ruling classifying the syrup under HTSUS subheading 1702.90.40, which avoided higher tariff-rate quota (TRQ) duties.
- Relying on the ruling, Heartland began importing and refining operations in the United States in 1997.
- Domestic trade associations petitioned under 19 U.S.C. § 1516; Customs announced intent to revoke the ruling and later reclassified the syrup under a TRQ-subject provision with higher duties.
- Heartland previously obtained pre-importation review in the Court of International Trade (CIT) under 28 U.S.C. § 1581(h), but the Federal Circuit later upheld Customs’ revocation and reclassification.
- A later dispute arose over the temporal reach of the reclassification and whether Customs could apply higher duties to entries associated with the earlier § 1581(h) litigation period.
- In 2003, Heartland filed a new CIT complaint again invoking § 1581(h) and contesting Customs’ retroactive duty treatment; the CIT dismissed for lack of subject-matter jurisdiction.
- Heartland appealed the jurisdictional dismissal to the Federal Circuit.

## Issues

1. Whether the CIT has ancillary jurisdiction to determine the scope and effect of its earlier § 1581(h) judgment, including the effective date and temporal reach of Customs’ reclassification.
2. Whether the CIT lacked subject-matter jurisdiction over Heartland’s 2003 complaint on the theory that § 1581(h) jurisdiction had been exhausted or lost after earlier proceedings.

## Decision

- The Federal Circuit reversed the CIT’s dismissal and remanded.
- The court held the CIT has ancillary jurisdiction to interpret and determine the scope and effect of its prior § 1581(h) decision.
- The court did not decide the merits of the effective-date or retroactivity dispute and left those questions for the CIT on remand.

## Legal Principles

- A court that properly exercised jurisdiction and issued a judgment retains ancillary jurisdiction to interpret, implement, and enforce the scope and effect of that judgment.
- The CIT’s authority under ancillary jurisdiction can include resolving disputes tied to implementation of a prior § 1581(h) judgment, such as the temporal application of agency action connected to the earlier ruling review.
- Dismissal for lack of subject-matter jurisdiction is improper where the later dispute is incidental to and dependent on clarifying the court’s earlier judgment within its ancillary power.

## Conclusion

The Federal Circuit held that the CIT retained ancillary jurisdiction to clarify the scope and effect of its prior pre-importation (§ 1581(h)) judgment and therefore could hear Heartland’s challenge concerning the temporal reach of Customs’ reclassification, requiring reversal of the jurisdictional dismissal and remand for merits proceedings.


Heartland By-Prods., Inc. v. United States, 424 F.3d 1244 (Fed. Cir. 2005)