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Administrative Agencies Administrative Proceedings

Offit Kurman

Quick Guide to Administrative Hearings

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Join the Litigators Lounge with Offit Kurman’s Anders Sleight and Niall McMillan as they dive into the nuances of administrative proceedings versus typical civil court cases, focusing on the process, discovery limitations,...more

Jackson Lewis P.C.

Enhanced AFCA Empowers Agency Fraud-Fighting, Creates Compliance Concerns for Federal Contractors and Others

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Significant revisions to the Program Fraud Civil Remedies Act of 1986 (PFCRA), now called the Administrative False Claims Act (AFCA), bolster federal agencies’ ability to address alleged fraud by expanding their authority to...more

Venable LLP

FTC Constitutional Challenge Update: Fifth Circuit Delivers Illumina a Stocking Full of Coal

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Last week, the Fifth Circuit handed down an across-the-board rejection of four constitutional challenges raised by gene sequencing company Illumina in defending against the Federal Trade Commission’s merger challenge. Bah!...more

American Conference Institute (ACI)

[Event] 23rd Annual Conference on Advanced Administrative Law & Practice - October 24th - 25th, Ottawa, ON, Canada

Attend the conference where Administrative Law practitioners – from across Canada and across sectors – come to find clarity in decision making. Canada’s administrative law sector continues to evolve to new demands. Backlogs,...more

Holland & Knight LLP

U.S. Supreme Court Agrees to Hear Nondelegation Case

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The U.S. Supreme Court on June 30, 2023, agreed to hear the case of SEC v. Jarkesy.1 The case is an appeal of a U.S. Court of Appeals for the Fifth Circuit decision that held that the U.S. Securities and Exchange Commission's...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Supreme Court Ruling Questions Constitutionality of FTC’s and SEC’s Administrative Adjudications Processes - Is OSHA Next?

On April 14, 2023, the Supreme Court of the United States opened the door for new challenges to the federal administrative state. In a unanimous decision in a pair of consolidated cases, Axon Enterprise, Inc. v. Federal Trade...more

Franczek P.C.

The Era of Fully Remote Board Meetings Is Over: Returning to Pre-COVID Remote Attendance Requirements

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As we announced on our blog last week, Governor Pritzker’s COVID-19 disaster proclamation ended on May 11. This signals the end of optional remote attendance at meetings and a return to pre-COVID era requirements for remote...more

BakerHostetler

Supreme Court Clears the Way for Constitutional Challenges to SEC, FTC Administrative Forums in Federal District Court

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In Axon Enterprise, Inc. v. FTC and SEC v. Cochran, the respondents in administrative agency enforcement actions brought suit in federal district court, challenging the constitutionality of each respective agency’s attempt to...more

Sheppard Mullin Richter & Hampton LLP

Supreme Court Holds That Respondents in Agency Enforcement Actions May Raise Constitutional Challenges Outside of Administrative...

On April 14, 2023, in a decision involving appeals regarding two separate agency enforcement actions, the Supreme Court unanimously held that respondents in such actions may raise certain constitutional challenges outside of...more

Holland & Knight LLP

Supreme Court's 9-0 Ruling Paves Way for Constitutional Challenges to Administrative Proceedings

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The U.S. Supreme Court on April 14, 2023, issued a unanimous opinion holding that federal district courts can consider constitutional challenges to administrative proceedings before such agencies issue final rulings. In Axon...more

WilmerHale

Jarkesy Case Upends SEC Tribunal

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On May 18, 2022, the US Court of Appeals for the Fifth Circuit issued its decision in Jarkesy v. SEC, vacating a Securities and Exchange Commission (SEC) decision in an enforcement action brought as an administrative...more

American Conference Institute (ACI)

[Webinar] 20th Annual Advanced Administrative Law & Practice - October 28th - 29th, 9:15 am - 5:00 pm EDT

The Canadian Institute’s 20th Annual Conference on Advanced Administrative Law and Practice returns this year, in a fully virtual and interactive format, to help you make sense of these developments, understand how you are...more

Sheppard Mullin Richter & Hampton LLP

New Executive Orders Aim to Eliminate Unfair Surprise in Civil Enforcement Actions by Formalizing Guidance Documents

On October 9, 2019, the President issued two executive orders that require agencies to formally provide official guidance before enforcing any new jurisdiction or legal standards. In other words, agencies cannot take novel...more

Jones Day

White House Executive Orders Limit Federal Agencies' Civil Enforcement Tools

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The president issued two executive orders limiting federal agencies' ability to use guidance documents for policymaking and enforcement and promoting transparency and fairness in civil enforcement matters....more

Carlton Fields

SEC Proceedings Face Uncertainty After Supreme Court Holds ALJs Unconstitutional

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After much anticipation, the U.S. Supreme Court ruled on the constitutionality of the Securities and Exchange Commission’s (SEC or Commission) Administrative Law Judges (ALJs)....more

Fisher Phillips

OSHA, Too? Will OSHA Citations Also Be Invalidated in the Wake of the Jones Brothers Case?

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After the Sixth Circuit Court of Appeals’ decision in Jones Brothers, Inc. v. Sec’y of Labor, citations upheld by administrative law judges within the Federal Mine Safety and Health Review Commission (“FMSHRC”) may be...more

Fisher Phillips

MSHA Citations Upheld by Administrative Law Judges Before April 3, 2018 May Be Invalid

Fisher Phillips on

Over the last few years, there has been debate regarding whether ALJs are “inferior officers” under the Appointments Clause of the Constitution. This provision provides that officers, including inferior officers, may only be...more

Knobbe Martens

The Federal Circuit Finds Tribal Sovereign Immunity does not Apply in IPR

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On July 20, 2018, the Federal Circuit held that tribal sovereign immunity is not available as a defense in IPR. Allergan Pharmaceuticals owned patents that it had asserted in litigation against various generic...more

Knobbe Martens

Saint Regis Mohawk Tribe v. Mylan Pharmaceuticals Inc.

Knobbe Martens on

Federal Circuit Summary - Before Dyk, Moore, and Reyna. Appeal from the Patent Trial and Appeal Board. Summary: Tribal sovereign immunity does not shield Indian Tribe owned patents from IPR. ...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

Federal Circuit Declares Tribal Sovereign Immunity Cannot Be Asserted In Inter Partes Review Proceedings

U.S. Court of Appeals for the Federal Circuit affirmed a U.S. Patent Trial and Appeal Board (PTAB) decision finding that tribal sovereign immunity does not apply to Inter Partes Review (IPR) proceedings. In so holding, the...more

Polsinelli

Lack of Presidential Appointment May Invalidate ALJ Decisions

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In one of its last opinions of the term, the U.S. Supreme Court held in Lucia v. U.S. Securities and Exchange Commission (SEC) on June 21, 2018, that administrative law judges (ALJs) are officers of the United States, not...more

Orrick, Herrington & Sutcliffe LLP

3 Key Defense Arguments For Post-Lucia SEC Proceedings

Orrick's Andrew Morris and Ben Aiken co-authored an article for Law360 in which they identify three of the most significant defense arguments for respondents in SEC administrative actions in light of the Supreme Court's...more

Carlton Fields

Supreme Court Set to Rule on Constitutionality of SEC’s ALJs

Carlton Fields on

In April, the U.S. Supreme Court heard oral argument in Lucia v. SEC to resolve the federal circuit court split on whether the SEC’s administrative law judges (ALJs) are "inferior officers" of the United States who must be...more

Vedder Price

SEC Administrative Law Judges: Key Takeaways and Lingering Questions from Lucia v. SEC

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On June 21, 2018, the United States Supreme Court resolved a circuit split on the question of whether administrative law judges (“ALJs”) of the Securities and Exchange Commission (the “SEC” or the “Commission”) qualify as...more

Ballard Spahr LLP

What does the Supreme Court’s Lucia decision mean for the CFPB and federal banking agencies?

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In its June 21 decision in Lucia v. Securities & Exchange Commission, the U.S. Supreme Court ruled that administrative law judges (ALJs) used by the SEC are “Officers of the United States” under the Appointments Clause in...more

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