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Appointments Clause Trump Administration Enforcement Actions

Epstein Becker & Green

Trump Fires Two Commissioners and Solidifies Control Over FTC

Epstein Becker & Green on

On March 18, 2025, President Donald Trump removed the two remaining Democrats serving on the Federal Trade Commission (FTC), Rebecca Slaughter and Alvaro Bedoya....more

Patterson Belknap Webb & Tyler LLP

Puerto Rico’s Restructuring: A Brief Update #2

When we last checked in on the Puerto Rico restructuring case, we reported on the February 15 decision of the First Circuit Court of Appeals that the members of the Financial Oversight and Management Board were appointed in...more

Carlton Fields

Circuits Split Over Constitutionality of SEC’s Administrative Law Judges

Carlton Fields on

The Tenth Circuit Court of Appeals, in Bandimere v. SEC, recently held that the SEC’s administrative law judges (ALJs) are “inferior officers” whose appointments violate the Appointments Clause of the U.S. Constitution...more

Cadwalader, Wickersham & Taft LLP

The Tenth Circuit Rules SEC Administrative Judges Are Unconstitutional, Setting Up Potential Supreme Court Review

The constitutionality of the SEC’s in-house administrative proceedings is in doubt following the 10th Circuit Court of Appeals’ ruling in Bandimere v. SEC. In Bandimere, a three-judge panel held, by a 2-1 decision, that SEC...more

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