News & Analysis as of

Administrative Proceedings

Orrick, Herrington & Sutcliffe LLP

Fifth Circuit upholds OCC enforcement action, finding Jarkesy ruling does not bar in-house proceedings

On September 8, the U.S. Court of Appeals for the Fifth Circuit denied a petition for review brought by two former executives of a failed Texas bank, upholding industry bans and $250,000 in civil penalties imposed by the OCC....more

Eversheds Sutherland (US) LLP

Unclaimed Property Exam Resurrected in Michigan by Zombie Theory of the Statute of Limitations

The Michigan Court of Appeals has resurrected the Michigan Treasurer’s efforts to enforce an unclaimed property examination assessment going back nearly 20 years by holding that the state’s issuance of an exam determination...more

Nelson Mullins Riley & Scarborough LLP

Federal Court Permits FTC Administrative Action Against Dealer Group to Continue—At Least for Now

A Texas federal court recently declined to enjoin an administrative action brought by the Federal Trade Commission (“FTC”) against Asbury Automotive Group (“Asbury”), one of the largest automobile dealer groups in the United...more

BCLP

Appeals Court Denies Challenge to SEC Rule Requiring Settling Parties not to Deny Liability

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The SEC’s longstanding practice of requiring settling parties not to deny the charges against them, denounced as the “gag rule” by critics, recently withstood another legal challenge. ...more

Mandelbaum Barrett PC

New York Cannabis Ruling: Businesses Can Raise Constitutional Challenges in OCM Administrative Hearings

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In a major legal win for New York cannabis licensees, Mandelbaum Barrett PC has secured a precedent-setting decision that strengthens the rights of businesses facing Office of Cannabis Management (OCM) enforcement actions....more

Warner Norcross + Judd

Reminder: Insurance Agents/Brokers Are Required to Notify the State of Criminal Prosecutions or Administrative Proceedings

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Michigan’s Department of Insurance and Financial Services (DIFS) requires insurance producers (individual agents/brokers and business agencies, collectively, “Insurance Producers”) to provide notice of certain criminal or...more

American Conference Institute (ACI)

[Event] Advanced Administrative Law & Practice - October 29th - 30th, Ottawa ON, Canada

Canadian administrative and public law continues to evolve, shaped by recent decisions from the Supreme Court and the Federal Court of Appeal. Join us for CI's 25th Annual Conference on Advanced Administrative Law and...more

Eversheds Sutherland (US) LLP

Not So Fast – NLRB Structure Unconstitutional According to the Fifth Circuit

In November 2022, a La Grange employee filed an unfair labor practice charge with the NLRB, which resulted in the regional office issuing a complaint in March 2024. La Grange sought injunctive relief with the US District...more

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

Fifth Circuit Decision on NLRB ALJs Raises Constitutional Questions for OSHRC Removal Protections

The Fifth Circuit Court of Appeals’ August 2025 decision that addressed the constitutionality of dual for-cause removal protections for administrative law judges (ALJs) at the National Labor Relations Board (NLRB) has...more

Jones Day

Cancellation of Claims Deemed An Inappropriate Sanction

Jones Day on

USPTO Acting Director Stewart sua sponte reconsidered and modified a previous Director Review decision that had affirmed cancellation of all 183 challenged claims as a sanction against patent owner Longhorn Vaccines. ...more

Troutman Pepper Locke

FDA Tobacco Civil Money Penalty Provisions Ruled Unconstitutional, but Not Enjoined Nationwide

Troutman Pepper Locke on

In early August, the U.S. District Court for the Northern District of Texas ruled that the civil money penalty (CMP) provision in the Food, Drug, and Cosmetic Act (FDCA) for tobacco products, 21 U.S.C. § 333(f)(9), is...more

Rothwell, Figg, Ernst & Manbeck, P.C.

July USPTO Guidance Sets Stricter Standards for Evidence in IPR Petitions

Acting Director of the USPTO, Coke Morgan Stewart, issued a memorandum last week that will change the way petitioners levy challenges to patents via inter partes review (IPR). The change will apply to any petition for IPR...more

Mayer Brown

Brasília em Pauta – Edição Nº 206

Mayer Brown on

Prezados e prezadas, O “Brasília em Pauta” é um boletim semanal preparado pela equipe de Contencioso de Brasília, contendo os principais casos a serem julgados pelo Supremo Tribunal Federal (STF), Superior Tribunal de...more

K&L Gates LLP

Return to In-Person Patent Trial and Appeal Board Hearings

K&L Gates LLP on

Effective 1 September 2025, all hearings before the Patent Trial and Appeal Board (PTAB) will be conducted in person. Parties involved must attend these hearings physically and in person unless they can demonstrate a valid...more

Foley & Lardner LLP

CMS Finalizes Rule Change Applying Preponderance of the Evidence Standard to Agent, Broker, and Web-Broker Exchange Agreement...

Foley & Lardner LLP on

In its recently issued Final Rule (CMS-9884-F; 90 FR 27074-01; the Final Rule), the Centers for Medicare and Medicaid Services (CMS) finalized revisions to 45 C.F.R. § 155.220(g)(2) to specify a standard of proof for...more

McDonnell Boehnen Hulbert & Berghoff LLP

Federal Circuit Special Committee Recommends Continued Suspension for Judge Newman

Inexorable, inevitable, and regrettable are three words that come to mind with publication from the Report from Special Committee of the Federal Circuit (composed of Chief Judge Moore and Judges Prost and Taranto)...more

Miles & Stockbridge P.C.

Bid Protests of State Procurements in the DMV - Virginia Procurements

In the Commonwealth of Virginia, decentralization is the rule. Virginia state law generally vests procurement authority in the individual agency or locality, where a protest can move very quickly from submission to the...more

ArentFox Schiff

USPTO Ends Remote PTAB Hearings Effective September 1

ArentFox Schiff on

The US Patent and Trademark Office (USPTO) has announced that, effective September 1, all PTAB hearings will be conducted in person at USPTO offices, marking a departure from the virtual and hybrid formats adopted in recent...more

Offit Kurman

Quick Guide to Administrative Hearings

Offit Kurman on

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

Bradley Arant Boult Cummings LLP

SEC Enforcement in the Second Quarter of 2025

In May 2025, we summarized the U.S. Securities and Exchange Commission’s (SEC) Division of Enforcement activity during the first quarter of the new presidential administration. With the second quarter now concluded, and Paul...more

Morgan Lewis

Los Angeles ‘Mansion Tax’ Update Regarding Office of Finance Assessments

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Taxpayer disputes involving Los Angeles’s Measure ULA, the Homelessness and Housing Solutions Tax—commonly referred to as the “mansion tax”—are progressing through the city’s administrative review process. Property owners...more

Jackson Lewis P.C.

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

Jackson Lewis P.C. on

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

Barnea Jaffa Lande & Co.

Israel Securities Authority Pecuniary Sanctions: Enforcement Tool or Rights Violation?

The Israel Securities Authority (ISA) has recently begun to take a clearly more aggressive approach toward administrative enforcement. Originally, pecuniary sanctions were intended to provide a swift, proportional, and...more

Nossaman LLP

The 411 on Special Commissioners’ Hearings in Texas

Nossaman LLP on

Every condemnation case in Texas must go through an administrative phase in which disinterested real property owners (who live in the county where the suit is filed) are appointed as Special Commissioners to assess the market...more

Shumaker, Loop & Kendrick, LLP

Client Alert: FINRA Issues Administrative Order and Decision Regarding Alpine Sanctions

On March 25, 2025, the Financial Industry Regulatory Authority (FINRA) issued a 100-page Administrative Order and Decision confirming and modifying its sanctions of Alpine Securities Corporation, which include expulsion from...more

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