News & Analysis as of

Removal For-Cause Constitutional Challenges Separation of Powers

Ballard Spahr LLP

Chief Justice allows Trump to fire FTC Commissioner Slaughter—at least for now

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Chief Justice John Roberts has issued a temporary stay allowing President Trump to fire recently reinstated FTC Commissioner Rebecca Slaughter, even though she was fired without cause....more

Phelps Dunbar

Fifth Circuit Finds NLRB’s Multilayer Removal Protections for Board Members and Administrative Law Judges Are Likely...

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On August 19, the U.S. Court of Appeals for the Fifth Circuit affirmed federal district court preliminary injunctions halting Unfair Labor Practice (ULP) proceedings before the National Labor Relations Board (NLRB). ...more

Genova Burns LLC

Fifth Circuit Panel Finds Unconstitutional Removal Protections Favoring NLRB Members And ALJs

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On August 19, 2025, a three-judge panel of the Fifth Circuit Court of Appeals ruled in a long-anticipated opinion that the NLRA’s protections for Board Members and Administrative Law Judges from presidential removal are...more

Ballard Spahr LLP

Federal Appeals Court rules that Trump illegally fired FTC board member, orders her reinstatement

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A divided federal appeals court has ruled that President Trump illegally fired Democratic FTC member Rebecca Slaughter and has ordered that she be reinstated to her position....more

Axinn, Veltrop & Harkrider LLP

D.C. Circuit Allows FTC Commissioner Slaughter to Be Reinstated, but the Supreme Court May Soon Decide Otherwise

Yesterday, the D.C. Circuit issued the latest decision in the saga over President Trump’s firing of the Democratic Federal Trade Commission (FTC) Commissioners. That decision sets the stage for a likely emergency application...more

Benesch

Fifth Circuit Expresses Significant Doubt on NLRB’s Constitutionality as Structured

Benesch on

On August 19, 2025, the Fifth Circuit ruled on consolidated appeals stemming from preliminary injunctions sought by—and granted to—three companies challenging the National Labor Relations Board’s (“NLRB”) structure. ...more

Franczek P.C.

SpaceX Wins Fifth Circuit Victory; Big Implications for NLRB

Franczek P.C. on

In an August 19, 2025 decision in SpaceX v. NLRB, the Fifth Circuit ruled that the structure of the National Labor Relations Board (NLRB) is likely unconstitutional and upheld three preliminary injunctions preventing the NLRB...more

Constangy, Brooks, Smith & Prophete, LLP

Bad news for Wilcox? Removal protections for NLRB members, ALJs are “likely” unconstitutional, appeals court finds

A three-judge panel of the U.S. Court of Appeals for the Fifth Circuit has upheld three orders that bar the National Labor Relations Board from pursuing unfair labor practice cases against SpaceX and two other employers. ...more

Nelson Mullins Riley & Scarborough LLP

Supreme Court Allows President Trump to Remove Democratic CPSC Commissioners

In a significant decision with broad implications for the structure and independence of federal regulatory agencies, the U.S. Supreme Court on July 23, 2025, granted President Trump’s request to remove three Democratic...more

McDonnell Boehnen Hulbert & Berghoff LLP

Judge Newman and the On-Going Attempts to Remove Her from the Federal Circuit

The efforts to have Judge Pauline Newman, Circuit Judge on the Court of Appeals for the Federal Circuit, unfit or guilty of misconduct have been the subject of reporting in the patent blogosphere (Patently-O, IP Watchdog),...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

Ballard Spahr LLP

Ninth Circuit rules CID issued to Seila Law was validly ratified by Director Kraninger

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Less than six weeks after hearing oral argument, a unanimous panel of the U.S. Court of Appeals for the Ninth Circuit ruled that the CID issued to Seila Law was validly ratified by Director Kraninger and affirmed the district...more

Herbert Smith Freehills Kramer

Fifth Circuit Agrees to Rehear En Banc Whether Federal Courts Can Decide Constitutionality of Removal Protections for SEC’s...

On Oct. 30, 2020, the Fifth Circuit agreed to rehear en banc a case challenging the constitutionality of Securities and Exchange Commission (SEC) administrative proceedings on the ground that the agency “is violating...more

Ballard Spahr LLP

After Seila Law, Will Congress Change the CFPB’s Leadership Structure?

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In the wake of the U.S. Supreme Court’s June 29, 2020 decision in Seila Law LLC v. Consumer Financial Protection Bureau, which held that the CFPB’s leadership structure violates the separation of powers mandated by the U.S....more

Lathrop GPM

The CFPB’s Future After Seila Law LLC v. Consumer Financial Protection Bureau

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In the wake of the 2008 financial crisis, Congress created the Consumer Financial Protection Bureau, an independent agency dedicated to consumer protection in the financial sector. The CFPB’s jurisdiction includes banks,...more

Hudson Cook, LLP

Supreme Court’s Seila Law Decision Brings Clarity to the CFPB (for Now)

Hudson Cook, LLP on

In June, the Supreme Court struck down the leadership structure of the CFPB as unconstitutional. (The case is Seila Law LLC v. CFPB, No. 19-7 (June 29, 2020), and the decision is here.) The case resolves a long-simmering...more

Bradley Arant Boult Cummings LLP

Small Dollar Rule Stay Requested to Be Lifted in Recent Joint Status Report

With the Supreme Court’s recent decision in Seila Law and Director Kathleen Kraninger’s ratification of the payment provisions of the Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule (the “Small Dollar...more

Akerman LLP

Impact of Supreme Court's Decision in "Seila Law, LLC v. CFPB"

Akerman LLP on

On June 29, 2020, the Supreme Court resolved the ongoing dispute regarding the structure of the Consumer Financial Protection Bureau (CFPB) in Seila Law LLC v. Consumer Financial Protection Bureau, 591 U.S. – (2020). In a 5-4...more

Brownstein Hyatt Farber Schreck

High Court’s Seila Law Decision Disappoints

On June 29, 2020, in Seila Law v. Consumer Financial Protection Bureau (CFPB), a divided Supreme Court held that the statute that created the CFPB is unconstitutional because it did not vest enough powers with elected...more

White & Case LLP

US Supreme Court Rules CFPB’s Leadership Structure is Unconstitutional but Leaves CFPB Intact

White & Case LLP on

On June 29, 2020, the Supreme Court of the United States ("Supreme Court") ruled that the single-director leadership structure of the Consumer Financial Protection Bureau ("CFPB" or "Bureau") violates the separation of powers...more

Ballard Spahr LLP

CFPB Ratifies Most Pre-Seila Law Regulatory Actions

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The CFPB has issued a ratification of “the large majority of its existing regulations” and certain other regulatory actions taken from January 4, 2012 through June 30, 2020 (Ratified Actions). ...more

Holland & Knight LLP

Supreme Court Saves CFPB, But Subjects Its Director to Removal at the Will of the President | Insights

Holland & Knight LLP on

The U.S. Supreme Court on June 29, 2020, issued its decision in Seila Law v. CFPB, a case in which the petitioner challenged the constitutionality of the Consumer Financial Protection Bureau (CFPB). While the Supreme Court...more

A&O Shearman

Supreme Court Concludes That Dodd-Frank's "For Cause" CFPB Director Removal Provision Violates Separation Of Powers, But Finds...

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On June 29, 2020, the United States Supreme Court, in a 5-4 decision authored by Chief Justice Roberts, held that the structure of the Consumer Financial Protection Bureau (“CFPB”), which permitted the President to remove the...more

Goodwin

Financial Services Weekly Roundup: The Supreme Court Strikes Back On Single Director Leadership Structures

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In This Issue. The U.S. Supreme Court struck down the single director leadership structure of the Consumer Financial Protection Bureau (CFPB) in a ruling that could have far-reaching implications for the CFPB and other...more

Cadwalader, Wickersham & Taft LLP

Seila Law LLC v. Consumer Financial Protection Bureau: Has the Supreme Court Tamed or Empowered the CFPB?

On June 29, the Supreme Court issued its long-awaited opinion in Seila Law LLC v. Consumer Financial Protection Bureau, finally resolving the question that has dogged the new agency since its inception:  Is the leadership...more

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