19 U.S.C. § 580

Interest in suits on bonds for recovery of duties

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Upon all bonds, on which suits are brought for the recovery of duties, interest shall be allowed, at the rate of 6 per centum a year, from the time when said bonds became due.

Notes of Decisions
Cited in 25 cases (1 in the last 5 years), 1983–2025 · leading case: United States v. Am. Home Assurance Co., 789 F.3d 1313 (Fed. Cir. 2015).
United States v. Am. Home Assurance Co., 789 F.3d 1313 (Fed. Cir. 2015). · cites it 10× “Second, the court held that the government was not entitled to statutory prejudgment interest under 19 U.S.C. § 580 on the amount due under the bond.”
United States v. Am. Home Assurance Co., 2014 CIT 7 (Ct. Intl. Trade 2014). · cites it 12× “The parties dispute (1) whether AHAC is liable for the unpaid duties as the surety on a continuous bond, and (2) assuming AHAC is liable, whether AHAC owes the Government both prejudgment interest in the form of equitable interest and interest pursuant to 19 U.S.C. § 580 (2006).…”
United States v. Am. Home Assurance Co., 2015 CIT 88 (Ct. Intl. Trade 2015). · cites it 8× “Over and above any antidumping duties and 1505(d) interest owed, the Government claims statutory pre-judgment interest as an exaction pursuant to 19 U.S.C. § 580 (“580 interest”) for having to commence these four collection actions.”
United States v. Am. Home Assurance Co., 2015 CIT 141 (Ct. Intl. Trade 2015). · cites it 12× “In addition, AHAC is liable for pre-judgment interest, post-judgment interest, equitable interest and interest pursuant to 19 U.S.C. § 580 .” (emphasis added)). Further, the Government specifically sought interest pursuant to § 1505(d) in its Complaint in court number 09-401.”
United States v. Great Am. Ins., 738 F.3d 1320 (Fed. Cir. 2013). · cites it 2× “The government ended its motion by asking for “the relief requested in the Complaint,” and it attached a proposed order awarding it the value of the bonds “plus interest in accordance with 19 U.S.C. § 580 .” PL’s Mot. Summ. J., United States v.”
United States v. Am. Home Assurance Co., 2015 CIT 120 (Ct. Intl. Trade 2015). · cites it 13× “The United States claims that AHAC is liable to Customs for: (1) unpaid antidumping duties; (2) statutory prejudgment interest pursuant to 19 U.S.C. § 580 , in excess of the bond amount; (3) post-liquidation interest under 19 U.”
United States v. Am. Home Assurance Co., 857 F.3d 1329 (Fed. Cir. 2017). · cites it 4× “American Home Assurance Company (“AHAC”) cross-appeals the Trade Court’s decision to award the government interest on the unpaid duties under 19 U.S.C. §§ 580 and 1505(d). Id. at 1371 .”
United States v. Great Am. Ins. Co. of New York, 229 F. Supp. 3d 1306 (Ct. Intl. Trade 2017). · cites it 6× “OPINION Barnett, Judge: The United States of America (“United States” or “Plaintiff’) sued Great American Insurance Company of New York (“GAIC” or “Defendant”) to recover *1310 $50,000 in unpaid antidumping duties and interest, the limit on a continuous entry-bond that GAIC…”
United States v. Am. Home Assurance Co., 2015 CIT 112 (Ct. Intl. Trade 2015). · cites it 3× “Following cross-motions for summary judgment, the court held AHAC liable for the unpaid duties, denied the government statutory prejudgment interest under 19 U.S.C. § 580 (2012), and awarded the government equitable pre- and postjudgment interest.”
United States v. Int'l Fid. Ins. Co., 2017 CIT 136 (Ct. Intl. Trade 2017). · cites it 5× “OPINION Gordon, Judge: This is a collection action by Plaintiff United States (“Plaintiff’ or “Government”) against Defendant International Fidelity Insurance Company (“Defendant” or “Fidelity”) as surety for unpaid anti-dumping duties, 1 plus statutory pre-judgment interest…”
United States v. Maverick Mktg., LLC, 2018 CIT 16 (Ct. Intl. Trade 2018). · cites it 2× “From AAIC, Plaintiff also seeks mandatory statutory interest pursuant to 19 U.S.C. § 580 . Compl. at ¶ 31. Plaintiff is also seeking attorney fees and any further interest, as provided by law, that the court deems just and appropriate.”
United States v. Atkinson, 575 F. Supp. 791 (Ct. Intl. Trade 1983). “As the government correctly acknowledges, the provisions in 19 U.S.C. § 580 are inapplicable for the reason that this action is to recover liquidated damages, not duties.”
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