News & Analysis as of

Federal Trade Commission (FTC) Administrative Proceedings Constitutional Challenges

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

Hogan Lovells

Constitutional challenges facing FTC may find receptive audience in nominee to lead the Commission

Hogan Lovells on

The Federal Trade Commission (FTC) is currently facing a growing number of challenges related to the constitutionality of the agency’s structure and operation. One of these challenges was raised by current FTC...more

Seyfarth Shaw LLP

Dealer Group Sues FTC to Enjoin Administrative Proceeding Over Alleged Junk Fees and Discriminatory Lending Practices - Seyfarth's...

Seyfarth Shaw LLP on

On October 4, 2024, Asbury Automotive Group, a Fortune 500 company and one of the largest automobile dealer groups in the United States, sued the Federal Trade Commission (FTC) to enjoin as unconstitutional the FTC’s...more

Bradley Arant Boult Cummings LLP

SpaceX Exploration: Constitutional Challenge to NLRB Structure

Following several complaints filed with the National Labor Relations Board (NLRB), SpaceX has mounted a constitutional challenge against the structure of the NLRB. Specifically, SpaceX contends that NLRB administrative judges...more

Axinn, Veltrop & Harkrider LLP

In SEC v. Jarkesy, Supreme Court Leaves Open Constitutional Challenges Related to FTC Structure and Process

In a much-watched case concerning the administrative state, on June 27, the Supreme Court decided in SEC v. Jarkesy that defendants facing a fraud suit by the SEC have a Seventh Amendment right to a jury trial in an Article...more

Venable LLP

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

Venable LLP on

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

Ballard Spahr LLP

SCOTUS to hear oral argument on Nov. 29 in case involving challenge to use of administrative law judges by federal agencies

Ballard Spahr LLP on

On November 29, 2023, the U.S. Supreme Court will hear oral argument in Jarkesy v. Securities and Exchange Commission, a case in which the respondents are challenging the constitutionality of the SEC’s use of administrative...more

A&O Shearman

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

A&O Shearman on

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

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

Troutman Pepper Locke

Administrative Law Judges Face Diminished Authority Under New FTC Rule

Troutman Pepper Locke on

On June 2, the Federal Trade Commission (FTC) announced modifications to its in-house adjudicative proceedings of agency challenges to mergers and acquisitions by reducing the decision-making power held by administrative law...more

Kelley Drye & Warren LLP

Déjà vu: The 5th Circuit Hears Yet Another Challenge to Constitutionality of an Administrative Agency

In the past couple years, the Federal Trade Commission has gone 0 for 2 before the Supreme Court. In AMG, the Court found that Section 13(b) of the FTC Act does not provide the Commission with the authority to obtain...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

A&O Shearman

Harbinger of cases to come: Axon decision sets the stage for future constitutional challenges to administrative proceedings

A&O Shearman on

Key Points - The U.S. Supreme Court held that litigants can bring constitutional challenges in federal district court against the FTC and SEC without fully exhausting administrative proceedings....more

Patterson Belknap Webb & Tyler LLP

Supreme Court Decision in Axon Enterprise, Inc. v. FTC Has Wide Reaching Implications for Administrative Enforcement Proceedings

On April 14, 2023, the Supreme Court issued a consolidated opinion in Axon Enterprise, Inc. v. FTC and SEC v. Cochran.[1] We previously covered the oral argument in these cases here. These cases address whether respondents...more

Jones Day

U.S. Supreme Court Paves the Way for Challenging Agencies' Structure in Federal District Court

Jones Day on

The U.S. Supreme Court holds that district courts have jurisdiction to hear constitutional challenges to the structure of Federal Trade Commission ("FTC") and Securities and Exchange Commission ("SEC") administrative...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

Carlton Fields

Axon, Gibson, Jarkesy: Continuing Challenges to SEC’s Administrative Citadel

Carlton Fields on

Earlier this month, the U.S. Supreme Court issued a procedural decision that has the potential to dismantle the Securities and Exchange Commission’s ability to litigate cases administratively. On April 14, 2023, the Supreme...more

Akin Gump Strauss Hauer & Feld LLP

SCOTUS Decision Sets Up Constitutional Challenges to FTC Administrative Proceedings

Key Points - In a unanimous decision, the Supreme Court held in Axon v. FTC that the FTC Act (and the SEC Act) do not prohibit a federal court from hearing challenges to the constitutionality of either Commission’s...more

Fisher Phillips

SCOTUS Delivers a Win for Businesses Challenging Federal Agency Actions: 4 Key Takeaways for Employers

Fisher Phillips on

The Supreme Court recently handed a victory to employers by giving them more tools to challenge federal agencies during administrative proceedings. Employers likely know how daunting it can seem to challenge federal officials...more

Troutman Pepper Locke

Unanimous Supreme Court Decision Allows for Early Challenges to Federal Agency Enforcement Actions

Troutman Pepper Locke on

On April 14, the Supreme Court unanimously held that federal district courts have jurisdiction to review constitutional challenges to the structures of the Federal Trade Commission (FTC) and Securities and Exchange Commission...more

Herbert Smith Freehills Kramer

SCOTUS Unanimously Holds That Respondents in FTC and SEC Administrative Law Proceedings May Challenge the Constitutionality of...

On April 14, 2023, the Supreme Court issued a unanimous decision in two related cases, Axon Enterprise, Inc. v. FTC (No. 21-86) and SEC v. Cochran (No. 21-1239), holding that respondents may challenge the constitutionality of...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

Hogan Lovells

U.S. Supreme Court clears the way for constitutional challenges to FTC, SEC

Hogan Lovells on

On April 14, 2023 the United States Supreme Court ruled in a unanimous opinion in Axon v. Federal Trade Commission that certain constitutional challenges to Federal Trade Commission (FTC) and Securities and Exchange...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

Troutman Pepper Locke

Supreme Court Hears Arguments on Challenges to Agency Enforcement Proceedings

Troutman Pepper Locke on

Do district courts have jurisdiction to hear constitutional challenges to federal agencies, or must plaintiffs first raise such challenges in administrative proceedings before the agency? On November 7, the U.S. Supreme Court...more

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