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Kemper AIP Metals, LLC v. United States

2026-08-07

Authorities cited

Opinion

majority opinion

Slip Op. 26-86

UNITED STATES COURT OF INTERNATIONAL TRADE

KEMPER AIP METALS, LLC AND

WAELZHOLZ BRASMETAL LAMINAÇÃO

LTDA.,

Plaintiffs, Before: Timothy M. Reif, Judge

v. Court No. 26-00762

UNITED STATES,

Defendant.

OPINION

[Granting proposed defendant-intervenors’ motions to intervene.]

Dated: August 7, 2026

John Anwesen, Lighthill PC, of Washington, D.C., for plaintiffs Kemper AIP Metals, LLC and Waelzholz Brasmetal Laminação Ltda.

Isabelle Aubrun, Trial Attorney, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, D.C., for defendant United States. Of counsel was Brien C. Stonebreaker, Attorney, Office of the Chief Counsel for Trade Enforcement and Compliance, U.S. Department of Commerce, of Washington, D.C.

James E. Ransdell IV, Thomas M. Beline and Margaret E. Monday, Cassidy Levy Kent (USA) LLP, of Washington, D.C., for proposed defendant-intervenor United States Steel Corporation.

Roger B. Schagrin, Jeffrey D. Gerrish and Nicholas C. Phillips, Schagrin Associates, of Washington, D.C., for proposed defendant-intervenors Steel Dynamics, Inc. and the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union, AFL-CIO, CLC.

Alan H. Price, Christopher B. Weld and Stephanie M. Bell, Wiley Rein LLP, of Washington, D.C., for proposed defendant-intervenor Nucor Corporation.

* * *

Court No. 26-00762 Page 2

Reif, Judge: Before the court are the motions to intervene of proposed defendantintervenors Nucor Corporation (“Nucor”), Steel Dynamics, Inc. (“Steel Dynamics”),

United States Steel Corporation (“U.S. Steel”) and United Steel, Paper and Forestry,

Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International

Union, AFL-CIO, CLC (“USW”) (collectively, “proposed intervenors”). See Partially

Unopposed Mot. to Intervene as a Matter of Right (“U.S. Steel Br”), ECF No. 11; Mot. to

Intervene as Def.-Intervenors (“Steel Dynamics and USW Br.”), ECF No. 15; Mot. to

Intervene as a Matter of Right (“Nucor Br.”), ECF No. 20.

Plaintiffs Kemper AIP Metals, LLC (“Kemper”) and Waelzholz Brasmetal

Laminação Ltda. (“Waelzholz Brasmetal”) oppose the motions on the grounds that

proposed defendant-intervenors “have no constitutional standing” and “do not qualify as

interested parties under 28 U.S.C. § 2631(j)(1)(B).” Opp’n to Mots. to Intervene (“Pls.

Br.”) at 2, ECF No. 26.

For the reasons discussed below, the court grants the motions to intervene.

BACKGROUND

The instant action arises from the affirmative determination of Commerce in the

antidumping duty (“AD”) investigation of certain corrosion-resistant steel products

(“CORE”) from Brazil for the period of investigation (“POI”) July 1, 2023, through June

30, 2024. Certain Corrosion-Resistant Steel Products from Brazil: Final Affirmative

Determination of Sales at Less than Fair Value (“Final Results”), 90 Fed. Reg. 42,219

(Dep’t Commerce Aug. 29, 2025) and accompanying Issues and Decision

Memorandum (“IDM”) (Dep’t of Commerce Aug. 25, 2025).

Court No. 26-00762 Page 3

On September 5, 2024, Commerce received an AD petition filed on behalf of

proposed defendant-intervenors and Wheeling-Nippon Steel, Inc., domestic producers

of CORE. Certain Corrosion-Resistant Steel Products from Brazil: Preliminary

Affirmative Determination of Sales at Less than Fair Value, Postponement of Final

Determination, and Extension of Provisional Measures (“Preliminary Results”), 90 Fed.

Reg. 15,333 (Dep’t of Commerce Apr. 10, 2025) and accompanying Preliminary

Decision Memorandum (“PDM”) at 1 (Dep’t of Commerce Apr. 3, 2025).

On April 10, 2025, Commerce issued the Preliminary Results and invited

comments from interested parties. Preliminary Results, 90 Fed. Reg. at 15,334. On

August 29, 2025, Commerce issued the Final Results. 90 Fed. Reg. 42,219.

On November 28, 2025, the U.S. International Trade Commission issued its final

affirmative injury determination and published its views on the same. See CorrosionResistant Steel Products from Australia, Brazil, Canada, Mexico, Netherlands, South

Africa, Taiwan, Turkey, United Arab Emirates, and Vietnam; Determinations, 90 Fed.

Reg. 55,320 (Dec. 2, 2025); see also Corrosion-Resistant Steel Products from Australia,

Brazil, Canada, Mexico, Netherlands, South Africa, Taiwan, Türkiye, United Arab

Emirates, and Vietnam, USITC Pub. 5678, Inv. Nos. 701-TA-733-736 and 731-TA-1702-1711 (Nov. 2025).

On December 19, 2025, Commerce issued the final AD order and assessed

duties on relevant entries of CORE. See Corrosion-Resistant Steel Products from

Brazil and Mexico: Amended Final Antidumping Duty Determination; CorrosionResistant Steel Products from Australia, Brazil, Canada, Mexico, the Netherlands,

South Africa, Taiwan, the Republic of Türkiye, the United Arab Emirates, and the Court No. 26-00762 Page 4

Socialist Republic of Vietnam: Antidumping Duty Orders, 90 Fed. Reg. 59,494 (Dep’t of

Commerce Dec. 19, 2025).

On February 19, 2026, plaintiffs filed their complaint in the instant action.

Compl., ECF No. 7.

On March 16 and 20, 2026, proposed intervenors filed the instant motions. See

U.S. Steel Br.; Steel Dynamics and USW Br.; Nucor Br.

JURISDICTION

28 U.S.C. § 1581(c) grants to this Court “exclusive jurisdiction of any civil action

commenced under section 516A or 517 of the Tariff Act of 1930.” Section 516A of the

Tariff Act of 1930 governs judicial review of determinations of Commerce in AD and

CVD proceedings. 1 See 19 U.S.C. § 1516a.

DISCUSSION

I. Constitutional standing

The court concludes that proposed intervenors have constitutional standing.

Plaintiffs argue that proposed intervenors “have no constitutional standing”

because “[t]hey neither assert an injury in fact traceable to the outcome of this litigation

nor claim piggyback standing by aligning themselves with the relief the United States

seeks.” Pls. Br. at 2.

In response, proposed intervenors argue that “Article III poses no obstacle where

proposed defendant-intervenors seek the same relief as the United States.” Resp. to

Opp’n to Mot. to Intervene (“Intervenors Br.”) at 7, ECF No. 28. Proposed intervenors

1 Further citations to the Tariff Act of 1930, as amended, are to the relevant portions of

Title 19 of the U.S. Code, 2018 edition.

Court No. 26-00762 Page 5

submit that they “do not seek to broaden the case, introduce new claims, or obtain any

relief different from that sought by the United States.” Id. at 8. Rather, the “only relief

Proposed Defendant-Intervenors seek is affirmance of [the] final determination” of

Commerce. Id.

The Supreme Court has stated that “[u]nder our precedents, at least one party

must demonstrate Article III standing for each claim for relief.” Little Sisters of the Poor

Saints Peter and Paul Home v. Pa., 591 U.S. 657, 674 n.6 (2020). Accordingly, “an

intervenor of right must have Article III standing in order to pursue relief that is different

from that which is sought by a party with standing.” Town of Chester v. Laroe Ests.,

Inc., 581 U.S. 433, 440 (2017) (emphasis supplied).

Put differently, “[w]here a putative intervenor seeks only the same relief as an

existing party to the litigation, the proposed intervenor may ‘piggyback’ on the existing

party’s standing.” HiSteel Co. v. United States, 46 CIT __, __, 592 F. Supp. 3d 1339,

1342 (2022) (citing Cal. Steel Indus., Inc. v. United States, 48 F.4th 1336, 1343 (Fed.

Cir. 2022)). And the U.S. Court of Appeals for the Federal Circuit has clarified that for

defendant-intervenors in a trade action, piggyback standing is established when “the

proposed intervenors’ requested relief is largely identical to the government’s prayer for

relief.” Cal. Steel Indus., 48 F.4th at 1343.

Plaintiffs do not dispute that proposed intervenors request only that the court

sustain the Final Results. See Pls. Br. Rather, the crux of plaintiffs’ argument is that

proposed intervenors neglected to argue explicitly that they possess constitutional

standing. See id. at 3-4. Given that the “only relief Proposed Defendant-Intervenors

seek is affirmance of [the] final determination,” Intervenors Br. at 8, the court concludes Court No. 26-00762 Page 6

that proposed intervenors have established implicitly constitutional standing. Plaintiffs

have failed to support their contention that constitutional standing must be argued and

established explicitly. See Pls. Br.

II. Intervention as a matter of right

The court concludes that proposed intervenors may intervene as a matter of

right.

Pursuant to U.S. Court of International Trade Rule 24(a), “[o]n timely motion, the

court must permit anyone to intervene who . . . is given an unconditional right to

intervene by a federal statute.”

28 U.S.C. § 2631(j)(1) provides that

Any person who would be adversely affected or aggrieved by a decision in

a civil action pending in the Court of International Trade may, by leave of

court, intervene in such action, except that . . . in a civil action under section

516A of the Tariff Act of 1930, only an interested party who was a party to

the proceeding in connection with which the matter arose may intervene,

and such person may intervene as a matter of right.

Id. (emphases supplied).

In the instant case, all proposed intervenors are “interested part[ies] who

[were parties] to the proceeding in connection with which the matter arose” such

that they all may intervene as a matter of right.

28 U.S.C. § 2631(k) specifies that “interested party” has the meaning

given in 19 U.S.C. § 1677(9), which includes

(C) a manufacturer, producer, or wholesaler in the United States of a

domestic like product, [and]

Court No. 26-00762 Page 7

(D) a certified union or recognized union or group of workers which is

representative of an industry engaged in the manufacture, production, or

wholesale in the United States of a domestic like product.

The court concludes that Nucor, Steel Dynamics and U.S. Steel are

“manufacturer[s] . . . in the United States of a domestic like product” in the instant

action.

It is undisputed that all three are manufacturers of subject merchandise.

See Pls. Br. at 1; Intervenors Br. at 2-3. 19 U.S.C. § 1677(10) defines “domestic

like product” as “a product which is like, or in the absence of like, most similar in

characteristics and uses with, the article subject to an investigation.” As

manufacturers of the “article subject to [the] investigation” itself, Nucor, Steel

Dynamics and U.S. Steel manufacture “a domestic like product” and are

therefore “interested parties.” Cf. Hitachi Metals, Ltd. v. United States, 949 F.3d

710, 717 (Fed. Cir. 2020) (“Hitachi cites no authority that precludes the

Commission from determining that the domestic like product and the subject

merchandise are coextensive.”).

The same logic applies to USW, which is undisputedly “a certified union or

recognized union . . . of workers which is representative of an industry engaged

in the manufacture . . . of a domestic like product.” 19 U.S.C. § 1677(9)(D); see

Pls. Br. at 1-2. 2

2 Plaintiffs argue that:

“The United Steelworkers represents a small portion of the

workforce. Union membership across private-sector manufacturing, like the brasscoated steel producers that are absent from this case, tends to be lower, with an overall rate of around 6.9% for private-sector industries in the United States.” Pls. Br. at 1-2. This argument is not relevant to the statute. See 19 U.S.C. § 1677(9)(D); see also H.R. Doc. No. 103-316, at 862 (1994) (“The Administration intends that labor have equal voice with management in supporting or opposing the initiation of an investigation.”). Court No. 26-00762 Page 8

Moreover, the proposed intervenors were “part[ies] to the proceeding in

connection with which the matter arose” because all four were petitioners in the

underlying investigation. 28 U.S.C. § 2631(j)(1); PDM at 1; see Laclede Steel

Co. v. United States, No. 96-1029, 1996 WL 384010, at *2 (Fed. Cir. July 8,

1996).

Proposed intervenors add that “[p]laintiffs’ theory would turn intervention

into a vehicle for relitigating the merits of the Commerce’s [sic] decision under the

guise of standing and would threaten to exclude the very parties Congress

expressly authorized to participate in § 1516a actions.” Intervenors Br. at 2.

Plaintiffs insist nonetheless that proposed intervenors should not be permitted to

intervene because proposed intervenors “do not produce or sell brass-coated

steel, nor do they understand the technical aspects of the product.” 3 Pls. Br. at 6.

Plaintiffs argue also that proposed intervenors’ purported lack of understanding

was “responsible” for the scope language in the Final Results that plaintiffs

challenge in this action. 4 Id. at 7.

Both arguments are premature. The intervention inquiry is predicated on

the nexus of the parties to the subject merchandise and their participation in the

3 Waelzholz Brasmetal produces brass-coated steel strip and Kemper imports brasscoated steel strip. See Compl. ¶¶ 1-2.

4 That scope language provides “certain flat-rolled steel products, either clad, plated, or

coated with corrosion-resistant metals such as zinc, aluminum, or zinc-, aluminum-, nickel- or iron-based alloys, whether or not corrugated or painted, varnished, laminated, or coated with plastics or other non-metallic substances in addition to the metallic coating.” See Final Results, 90 Fed. Reg. at 42,222 (emphasis supplied). The term “such as” indicates a non-exhaustive list. See Such As, Merriam-Webster Online Dictionary, https://www.merriam-webster.com/dictionary/such%20as (last visited July 30, 2026) (“used to introduce an example or series of examples”).

Court No. 26-00762 Page 9

underlying proceeding. See 28 U.S.C. § 2631(j)(1). It would be inappropriate at

this stage for the court to look beyond these questions at the legal issues that

form the substance of plaintiffs’ action. 5 See Compl. ¶¶ 18-21.

The decision to allow intervention here does not have any impact on the

subsequent adjudication of plaintiffs’ claims. Just as the court is not prepared at

this time to deny intervention on the grounds proffered by plaintiffs as that would

prejudge factual and legal issues that go to the merits of plaintiffs’ claims, so the

court’s ruling does not prejudge issues in favor of intervenors. Any attempt to

conflate intervention and the merits constitutes an erroneous reading of the

statute and the rules of this Court.

For these reasons, the court concludes that proposed intervenors “may

intervene as a matter of right.” 28 U.S.C. § 2631(j)(1).

CONCLUSION

For the reasons discussed above, proposed intervenors’ motions to intervene are

hereby GRANTED.

SO ORDERED.

5 The court underscores that this matter represents an attempt by plaintiffs to litigate the

substance of the dispute in the guise of opposing a motion to intervene. In this way, plaintiffs’ action constitutes both a misconstrual and a misuse of the process under the Rules of the Court. Such a misuse causes the Court, the government and other parties to expend resources unnecessarily. Parties are reminded that they are Officers of the Court and are responsible, consistent with ethical rules, to act as such. Opposing an intervention motion on grounds that self-evidently go to the merits of a matter represents a failure to act as an Officer of the Court. The court encourages parties in the future to avoid this wasteful use of its and others’ finite resources. Court No. 26-00762 Page 10

/s/ Timothy M. Reif

Timothy M. Reif, Judge

Dated: August 7, 2026

New York, New York