## Facts

- Schott Optical Glass, Inc. imported seven types of optical filter glass used in instruments such as spectrometers, spectrophotometers, and solar filter simulators.
- Two types were nearly colorless filters transmitting visible light while absorbing certain ultraviolet or infrared wavelengths.
- Five types were dark filters absorbing most visible light while transmitting ultraviolet or infrared light.
- Customs classified the merchandise as “other optical glass” under item 540.67 of the Tariff Schedules of the United States (TSUS).
- Schott protested, asserting that six types were properly classified as “colored or special glass” under item 542.92 TSUS and one type as “ordinary glass” under item 542.42 TSUS.
- In earlier litigation between the same parties involving similar glass, the Court of Customs and Patent Appeals affirmed classification as “optical glass” under item 540.67, based on a characterization that optical glass was presumed to be very high quality, used for optical instruments, and capable of performing an optical function.
- In this case, Schott offered additional evidence (including testimony concerning manufacturing processes and quality standards) that it contended was not presented previously and would show the earlier assumptions about quality and classification were incorrect or inapplicable.
- The Court of International Trade (CIT) treated the earlier decision as controlling stare decisis and refused to admit Schott’s proffered evidence, then sustained Customs’ classification.

## Issues

1. Whether the CIT erred by treating its prior classification decision as binding stare decisis that foreclosed Schott from introducing new evidence to show the prior decision was clearly erroneous or distinguishable.
2. Whether the CIT’s exclusion of evidence improperly prevented development of a factual record necessary to decide the tariff classification question.

## Decision

- The Federal Circuit reversed the CIT’s judgment and remanded.
- The court held the CIT misapplied stare decisis by treating its prior decision as an absolute bar to reconsideration and by excluding evidence offered to show clear error or factual distinction.
- The court directed the CIT on remand to admit Schott’s proffered evidence and then determine, on the full record, whether the earlier decision should be followed or departed from.
- The Federal Circuit did not decide the correct TSUS classification of the glass; it limited its ruling to the procedural error in refusing to consider new evidence.

## Legal Principles

- A trial court’s prior decisions are entitled to significant weight, but they do not operate as unchangeable precedent that prevents re-examination in later cases.
- Stare decisis at the trial-court level permits departure from prior decisions upon a sufficiently strong showing, including a showing that the earlier decision may be clearly erroneous or inapplicable to materially different facts.
- In customs classification disputes, factual determinations about a product’s physical characteristics, quality, and use are often central; excluding relevant evidence can improperly fix earlier factual assumptions without testing them against the current record.
- Where a party offers substantial new evidence bearing on a prior classification determination, the court must allow development of the evidentiary record before deciding whether the earlier ruling should control.

## Conclusion

The Federal Circuit required the Court of International Trade to allow Schott to present new evidence challenging the assumptions underlying an earlier tariff-classification decision and to reconsider whether that prior ruling should govern, rather than treating stare decisis as a categorical bar to factual development and re-examination.


Schott Optical Glass, Inc. v. United States, 750 F.2d 62 (Fed. Cir. 1984)