News & Analysis as of

Constitutional Challenges Administrative Proceedings Appeals

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

Davis Wright Tremaine LLP

5th Circuit Holds That Jarkesy Invalidates FCC Forfeiture Order Against AT&T

The U.S. Court of Appeals for the 5th Circuit held that the Federal Communications Commission (FCC or Commission) violated AT&T's Seventh Amendment right to a jury trial and right to adjudication by an Article III court when...more

Wiley Rein LLP

Fifth Circuit Strikes Down FCC Forfeiture Order, Holds That It Violates Seventh Amendment Right to a Jury Trial

Wiley Rein LLP on

On April 17, 2025, the Fifth Circuit issued an opinion (“Op.”) holding unconstitutional a Federal Communications Commission (FCC or Commission) enforcement order. In that order, the Commission imposed civil penalties against...more

Mayer Brown

Brasília em Pauta – Edição Nº 193

Mayer Brown on

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 Justiça (STJ) e Tribunal de...more

Perkins Coie

District Court Rules SpaceX Likely To Succeed in Challenging NLRB Constitutionality

Perkins Coie on

Judge Alan Albright of the U.S. District Court for the Western District of Texas issued an order on July 23, 2024, granting Space Exploration Technologies Corporation’s (SpaceX) motion for a preliminary injunction after...more

A&O Shearman

United States Supreme Court To Hear Appeal On SEC Power To Initiate Administrative Proceedings

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On June 30, 2023, the United States Supreme Court agreed to hear an appeal regarding the constitutionality of administrative proceedings in the case of George Jarkesy and Patriot28 LLC v. SEC, which could have important...more

Jones Day

Fifth Circuit Finds SEC Administrative Proceedings Unconstitutional

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On May 18, 2022, the Court of Appeals for the Fifth Circuit ruled that key aspects of the SEC's in-house enforcement regime for securities fraud cases were unconstitutional. The decision, Jarkesy v. SEC, has significant...more

Proskauer - Corporate Defense and Disputes

Fifth Circuit Holds SEC’s In-House Courts and Judges Unconstitutional

In Jarkesy v. Securities and Exchange Commission, the Court of Appeals for the Fifth Circuit issued a remarkable opinion holding numerous aspects of the SEC’s administrative enforcement regime are unconstitutional. The May...more

WilmerHale

D.C. Circuit Forfeiture Holding Highlights Importance of Involving Litigation Counsel in the Early Stages of Administrative Agency...

WilmerHale on

On February 26, 2021, in Springsteen-Abbott v. Securities and Exchange Commission, a panel of the U.S. Court of Appeals for the D.C. Circuit held that a petitioner challenging sanctions imposed by the Financial Institutions...more

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

Federal Circuit Appeals from the PTAB and ITC: Summaries of Key 2020 Decisions

[co-author: Kathleen Wills] Last year, the global COVID-19 pandemic created unprecedented challenges for American courts. By making several changes, however, the U.S. Court of Appeals for the Federal Circuit was able to...more

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

PTAB Strategies and Insights - August 2020: Appeals Raise Constitutional Challenge to PTAB Fee and Compensation Structure

Appellants in New Vision Gaming & Development v. SC Gaming, Inc. f/k/a Bally Gaming, Inc. and Mobility Workx, LLC v. Unified Patents, LLC challenge the constitutionality of the administrative patent judge (APJ) incentive...more

Jones Day

Parties Seek To Preserve Arthrex Rights Despite Waiver Ruling

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Following on Judge Newman’s dissent in Sanofi-Aventis Deutschland GmbH v. Mylan Pharmaceuticals Inc., parties are seeking to preserve their rights by challenging the Federal Circuit’s holding that a party’s failure to raise...more

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

PTAB Strategies and Insights - November 2019

The PTAB Strategies and Insights newsletter provides timely updates and insights into how best to handle proceedings at the USPTO. It is designed to increase return on investment for all stakeholders looking at the entire...more

Troutman Pepper Locke

Inter Partes Review of Pre-AIA Patents is Constitutional

Troutman Pepper Locke on

Celgene Corp. v. Peter, Appeal Nos. 2018-1167, -1168, -1169 (Fed. Cir. July 30, 2019) - Celgene owned two patents that pertained to methods of safely distributing potentially hazardous drugs.  The patents were challenged...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

Stinson LLP

Administrative Law Judge Appointments Continue to be Found Unconstitutional

Stinson LLP on

On July 31, the Sixth Circuit Court of Appeals decided that administrative law judges (ALJs) within the Mine Safety and Health Administration (MSHA) are "inferior officers" and therefore subject to the Constitution's...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

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

PTAB Strategies and Insights - July 2018

The PTAB Strategies and Insights newsletter provides timely updates and insights into how best to handle proceedings at the USPTO. It is designed to increase return on investment for all stakeholders looking at the entire...more

Sheppard Mullin Richter & Hampton LLP

Lucia Is Likely To Have Little Impact On Waning FCC Adjudications

During its most recent Term, the Supreme Court held in Lucia v. SEC that the administrative law judges (“ALJs”) that preside over adjudications at the Securities and Exchange Commission (“SEC”) are “Officers of the United...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

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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

Jones Day

U.S. Supreme Court Holds SEC's Staff Appointments for Administrative Law Judge Unconstitutional

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In Lucia v. SEC, the U.S. Supreme Court made things messy for the Securities and Exchange Commission ("SEC") by vindicating constitutional concerns over the agency's use of administrative law judges. The Court concluded that...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

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