News & Analysis as of

Administrative Law Judge (ALJ) Administrative Agencies Constitutional Challenges

Holland & Knight LLP

Fifth Circuit: Dual Removal Protections for NLRB ALJs, Board Members Likely Unconstitutional

Holland & Knight LLP on

In issuing a preliminary injunction in Space Exploration Technologies Corp. v. National Labor Relations Board, No. 24-50627 (5th Cir. 2025), the U.S. Court of Appeals for the Fifth Circuit held that the structure of the...more

Venable LLP

Tracking the Impact of Securities and Exchange Commission v. Jarkesy and Other Constitutional Challenges Against the FTC

Venable LLP on

In recent years, independent agencies have continued to face a number of constitutional and statutory challenges before the Supreme Court. AMG Capital Management struck down the Federal Trade Commission’s authority to obtain...more

Holland & Knight LLP

U.S. Supreme Court Agrees to Hear Nondelegation Case

Holland & Knight LLP on

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

BakerHostetler

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

BakerHostetler on

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

Perkins Coie

Supreme Court Allows Structural Constitutional Challenges to FTC and SEC Proceedings in Federal District Court

Perkins Coie on

The U.S. Supreme Court ruled in two related cases, Axon Enterprise Inc. v. FTC (No. 21-86) and SEC v. Cochran (No. 21-1239), that federal district courts have jurisdiction to hear structural constitutional challenges to the...more

Ballard Spahr LLP

SCOTUS decision allowing constitutional challenges to FTC and SEC to be brought in federal district court has broader implications

Ballard Spahr LLP on

The U.S. Supreme Court ruled last week that parties seeking to challenge the constitutionality of the structure of the Federal Trade Commission and the Securities and Exchange Commission cannot be required to raise such...more

Miller Canfield

Supreme Court Expands the Path to Challenge the Authority of Administrative Agencies in Federal Court

Miller Canfield on

Consistent with federal courts’ recent pattern of limiting the reach of administrative agencies, the Supreme Court held on April 14, 2023, that a challenge to the constitutional authority of an administrative law judge...more

Holland & Knight LLP

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

Holland & Knight LLP on

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

Epstein Becker & Green

Court’s Ruling Against FTC and SEC May Signal Future Limits on Agency Autonomy: SCOTUS Today

Epstein Becker & Green on

While the substantial backlog of decisions has many observers waiting for a flood of rulings, the Supreme Court is moving at its own pace. Thus, the Court has issued a single opinion today, but especially for readers who are...more

Proskauer - Corporate Defense and Disputes

Supreme Court Holds that Constitutional Challenges to Administrative Agencies’ Structure Can Be Brought in District Court

The Supreme Court held today that constitutional challenges to administrative agencies’ structure can be brought in federal district court and need not be raised through an administrative proceeding with subsequent appellate...more

WilmerHale

Jarkesy Case Upends SEC Tribunal

WilmerHale on

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

Proskauer - Minding Your Business

The Administrative State Under Attack: Potentially Far Reaching Implications of Supreme Court’s Decision to Hear Challenge to FTC...

In 1984, the Supreme Court ruled unanimously that courts must defer to an administrative agency’s reasonable interpretation of an ambiguous statute. But last year, the Supreme Court stripped the FTC of its ability to seek...more

Sheppard Mullin Richter & Hampton LLP

Axon Sues FTC Over Use of Administrative Adjudication in Merger Investigations

On January 3, 2020, Axon Enterprises Inc. filed a complaint against the Federal Trade Commission in the United States District Court for the District of Arizona challenging the constitutionality of the FTC’s administrative...more

Carlton Fields

SEC Proceedings Face Uncertainty After Supreme Court Holds ALJs Unconstitutional

Carlton Fields on

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

Polsinelli

Lack of Presidential Appointment May Invalidate ALJ Decisions

Polsinelli on

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

Vedder Price on

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?

Ballard Spahr LLP on

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

K&L Gates LLP

Supreme Court Offers Others a Chance for a Second Bite at the Apple in Federal Administrative Adjudication Proceedings – But the...

K&L Gates LLP on

On June 21, 2018 the U.S. Supreme Court ruled in Lucia et al. v. Securities and Exchange Commission, [1] that the appointment of certain administrative law judges (“ALJs”) was unconstitutional, and that those with matters...more

Herbert Smith Freehills Kramer

Supreme Court Rules the SEC’s Procedure for Appointing Administrative Law Judges Violates the Constitution’s Appointments Clause

On June 21, 2018, the Supreme Court in Raymond J. Lucia, et al. v. SEC, held that the SEC’s administrative law judges are “Officers of the United States” whose appointment must comport with the requirements of the...more

Tonkon Torp LLP

Supreme Court Throws Out SEC Administrative Law Judge Process

Tonkon Torp LLP on

On June 21, 2018, the Supreme Court of the United States invalidated the process that the Securities and Exchange Commission ("SEC") had been using to appoint administrative law judges. Staff from the SEC had selected...more

Morrison & Foerster LLP

Lucia Leaves Many Important Questions Unanswered

In Lucia v. U.S. Securities and Exchange Commission, Justice Elena Kagan, writing for a six-justice majority, presents the U.S. Supreme Court’s decision as both narrow and uncomplicated. “The sole question” the court chose to...more

Akin Gump Strauss Hauer & Feld LLP

Government Agencies Face Uncertainty After Supreme Court Rules That SEC ALJs Must Be Appointed

• SEC ALJs are “Officers of the United States” within the meaning of the Appointments Clause and therefore must be appointed directly by the SEC. The Court’s decision may permit litigants in prior and pending administrative...more

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