The Way We Was (and How We Got Here): A Brief History of the Practice of Trade Law in the U.S.

by Simon Lester & Petros C. Mavroidis*

*WorldTradeLaw.Net & Columbia Law School respectively.

1. Trade Practice, Then and Now

It is funny but when we think of the top trade practitioners these days, instinctively we think of big law firms with a group of trade lawyers as one part of a larger practice. It has not always been like that. The scale has changed, and with it some of the human touch, quirkiness, and personality may have been lost. This was not a working assumption when we started this project, but rather a discovery. When we decided to turn to the pioneers in our profession, and pick up the trail from the sixties and the seventies, when the trade law practice was taking its first steps in this country, we had no idea what to expect. We ended up in awe of the individuals who were our role-models when we were younger. They all responded beyond the call of duty and were eager to share their experiences with us in shaping this short account.

Through these discussions, we (re-)discovered not only the personalities involved, but also the ethos of an era. 

We might have waited too long to delve into something as worthy as this. And we have lost as a result some accounts that we could (and would) have profited from. But their stories live on in the memories of those to whom we have reached out, who eagerly spoke for those absent as well. We have discovered angles that we had never thought of, confirmed intuitions, and dismissed urban legends that persisted for no fathomable reason. Their stories unfold in what follows next. 

2. The Cast (in Alphabetical Order)

The pioneers of the trade law practice, the trailblazers that honored us with their time, are: Don Cameron, David Gantz, David Palmeter, Terry Stewart, and Alan Wolff. These are some of the names that dominated international trade practice in Washington D.C. in the previous decades. They spoke for Mike Daniels and David Houlihan too, and for the many others who are not with us anymore, and/or were hard to reach.   

They literally started from scratch. They had to pave the way for all of us that have followed ever since. In the 1960s and 1970s, international trade law was an exotic feature in any law school curriculum, including the top schools in the country. John H. Jackson taught it of course at the University of Michigan, and so did Robert E. Hudec first at Yale and then at Minnesota, and Kenneth Dam (in the realm of a wider course) at the University of Chicago. And this was pretty much where the buck stopped. Jackson’s 1969 book was the catalyst. He brought it all together under one roof, and provided thus the impetus for seriously studying the material. 

These legal scholars were not alone in their study of trade policy of course. Economists were also studying trade agreements, and while not trained in law, their analysis provided great insight into the meaning of these agreements. The writings of Robert Baldwin, Jagdish Bhagwati, Michael Finger, and Anne Krueger influenced the thinking of many of the trade lawyers mentioned above. And Gary Hufbauer bridged the two fields, with degrees in both law and economics. 

3. Trade Law Practice in the Tokyo Round (1973-1979)

We pick up the trail from the Tokyo Round for various reasons. First, beforehand, there was scarcely much of a trade law practice anyway, both at the domestic and the international plane. Only a few disputes had been raised before the GATT (General Agreement on Tariffs and Trade) CONTRACTING PARTIES, the highest organ of the GATT, and private trade lawyers did not play much of a role in these diplomatically-oriented disputes. Most of the trade practice in the U.S. was before U.S. domestic authorities and concerned the understanding and interpretation of U.S. trade statutes. U.S. trade law was closely connected to GATT law, as the U.S. drafters of the GATT had that trade law in mind as the foundation, but GATT law had not been transposed within the U.S. legal system “lock, stock, and barrel”. 

Second, with regard to those domestic authorities, the Tokyo Round signals the first serious attempt to add detail to contingent protection instruments (the so-called "trade remedies"), the bread and butter of trade practitioners. The agreed international framework of course “fed” the legal profession in Washington, D.C. that was engaging in trade consultancy and litigation. The U.S. legislation implementing the Tokyo Round fundamentally changed the U.S. trade law practice, which had been much less "legal" than what we are used to today. Prior to the Tokyo Round, trade lawyers would, in a sense, negotiate anti-dumping and countervailing duty rates with the Treasury Department, rather than litigate the way they do now. 

Third, immediately after the conclusion of the Tokyo Round, the first GATT (the predecessor of the World Trade Organization (WTO)) Legal Office (1981) was established, and it paved the way for the “judicialization” of trade disputes. 

Fourth, at the end of the Tokyo Round, the number of GATT Contracting Parties had reached record heights and other things equal one would expect that more governments and more agreements should lead to more disputes (and hence increase the need for legal advice). The data amply proves this point. Nevertheless, the Tokyo Round did not change the ratio of the litigation before U.S. domestic authorities as compared to litigation before the GATT. The former still dominated by and large the latter. Trade lawyers inside the Beltway were largely occupied with domestic U.S. trade law. As the numbers were not picking up sufficiently, they were all employed in the equivalent of “pa and ma stores”, as mega law firms with an army of experts were still a thing of the future for the trade law practice. 

3.1 How Does One Become a Trade Lawyer?

Until 1969, when Jackson’s classic was published, there was nothing much that practitioners could lean on for knowledge of the GATT other than accounts of the failed ITO negotiation, and a couple of volumes dealing with the negotiation of specific trade rounds. Actually, a healthy percentage of the original trade lawyer cast had not taken a complete course on international trade. 

Most of them were self-taught, and a pattern emerged (not for all, but definitely for a healthy percentage of the early practitioners): first, government service, where they would learn the tricks of the trade dealing with U.S. trade policy, followed by immersing into private trade practice when the timing was right. 

The occasional safeguard or antidumping or countervailing duty investigation would provide a good opportunity for foreign governments to hire some of the people mentioned above. During the Carter Presidency (1976-1980) safeguards were en vogue, and a few jumped to the boat of a boutique law firm dealing with the exotic subject of international trade. 

3.2 The Original Actors

In the 1970s and 1980s, there was no need for behemoths. Trade practice was not only absent from the curriculum of most law schools, but also a very idiosyncratic facet of law practice. It is no exaggeration at all to state that trade practice was self-contained and largely dedicated to customs-related issues and trade remedies. The days of “Trade and …” were far, far away. 

Unsurprisingly, the original cast was employed in boutique law firms. Names that have long disappeared, like Daniels, Houlihan and Palmeter, Stewart & Stewart, Tanaka Ritger (especially for Japanese clients), and Arter Hadden Hemmindinger, were almost monopolizing trade practice at the time. 

4. Trade Practice at the Advent of the Uruguay Round and Beyond

The end of the Tokyo Round held the promise of increasing legalization of trade law, and the establishment of the GATT Legal Office was the loudest signaling mechanism to this effect at the international level. It also carried with it the feeling of “unfinished business”. The U.S. request for expansion to trade in services was not adhered to. In similar vein, the EU had refused to do justice to the early promises of the “de Zeeuw group” (headed by a Dutch diplomat) to opt for a more rational agreement on farm trade. And the world was sliding towards the "end of history" moment, as per Fukuyama’s unfortunate (or maybe too optimistic) description. Change was palpable, and change would unavoidably bring with it a change in the profession as well.   

4.1 Re-inventing the Trade Lawyer

“Can’t teach new tricks to an ol’ dog” as the saying goes, but all is relative in real life. The advent of the Uruguay Round agreements was not a mere expansion of the Tokyo Round package. It was as close as possible to what sometimes people call a “paradigm shift” (a term very often abused in literature, but not this time). The single undertaking entailed that all WTO members were now members to practically all trade agreements. Government procurement was the only outlier, as the other three plurilaterals were one way or the other subsumed under the disciplines of other agreements. 

But GATS and TRIPS were added, as well as the SPS Agreement. Suddenly, in addition to the traditional customs and trade remedies practices, trade lawyers had to become conversant in trade in services, trade and health, and also intellectual property rights. To be fair, there is practically no one that spans the whole spectrum of WTO law with equal mastery. It was time for specialization, and with it came the time for joining forces. 

4.2 The Main Actors

The period following the Tokyo Round (1973-1979), and into the era of the Uruguay Round negotiations (1986-1994), coincides with the advent of trade teams within large law firms, which enabled collaboration between experts in different departments. Next to the boutique law firms mentioned above, bigger outfits entered the market. Skadden Arps, Dewey Ballentine, Mudge Rose, Covington, and Willkie Farr expanded into trade, often by acquiring the talent of smaller firms. 

The new highs in GATT/WTO membership led to enough demand for more players. More players, and more agreements, should signal, other things equal, more disputes, hence more work for trade practitioners. And indeed this is what happened. Between 1995-2019 the WTO dispute adjudication workload passed from roughly five cases per year during the GATT-era to twenty five per year. This all came to an abrupt end when the Appellate Body was led to abeyance by the Trump Administration, and at this stage it is unclear what comes next, as the MPIA has so far failed to entice the masses. Furthermore, the de facto abstention of the U.S. has probably provoked a fragmentation “doom loop,” as for many trading partners the new equation (WTO-U.S.) is not very attractive and certainly no reason to litigate. The numbers do tell a story in this respect. 

4.3 Domestic and WTO Trade Practice Re-Visited

At this juncture, it is far from clear as to what we should be expecting. WTO adjudication looks increasingly like a black box: time passes by, the numbers do not pick up, as the U.S. administration does not change its position regarding the resurrection of the Appellate Body, and the MPIA has failed to attract some significant holdouts.

On the other hand, recently in the U.S. we observe a surge in domestic trade law practice, as the Trump administration's aggressive use of older trade statutes has resulted in trade lawyers pursuing challenges to the constitutionality and legality of the various tariffs imposed, and/or requesting reimbursement of tariffs perceived as illegal. WTO law may only be playing a limited role at the moment, but the U.S. trade law practice is busier than ever. What happens after President Trump's term ends is, of course, a mystery at the moment. 

5. Looking Back

We started this inquiry trying to understand whether today’s trade practice is path dependent, some sort of emulation of the work of the trailblazers. We came to realize that the original cast accomplished something unique. With little formal training, largely through learning-by-doing, they managed to persuade the market to trust trade adjudication. We, the people who followed, have profited as much from their input as we did from more formal training. The history of trade adjudication is not simply the various legal precedents that emerge over time. It is the people behind the submissions that led to the precedents, the people like the amazing individuals who agreed to talk to us, and share their experiences from the moment they “wet their feet” in the stream that became the ocean of WTO and international trade law.