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Supreme Court Ends Use of Universal Injunctions

On June 27, 2025, in a 6-3 opinion by Justice Amy Coney Barrett, the U.S. Supreme Court held in Trump v. CASA, Inc., No. 24A884, 606 U.S. ___ (2025), that federal courts lack the power to issue “universal injunctions,” a...more

Higher Education Institutions Cautioned Against Misleading Statements About External Service Providers

On Jan. 14, 2025, the U.S. Department of Education issued guidance through a Dear Colleague Letter that, if left in place by the new administration, could significantly expand Federal Student Aid program reviews, attorney...more

Education Department to Formally Rescind 2023 Dear Colleague Letter on Third-Party Servicers

The U.S. Department of Education announced it will formally rescind the 2023 Dear Colleague Letter (DCL) on Third-Party Servicers (GEN-23-03) by Nov. 18, 2024. As explained in our prior Feb. 21, 2023, and April 12, 2023,...more

Supreme Court Opens Door to New Legal Challenges to Federal Regulations New and Old

Two cases decided at the end of the October 2023 Supreme Court term opened the door to new challenges to even longstanding federal regulations and may have enduring effects on the ability of agencies to implement their...more

Supreme Court Holds That SEC Must Seek Civil Penalties in Federal Court

In SEC v. Jarkesy, No. 22-859, 603 U.S. __ (2024), the Supreme Court held that the Seventh Amendment prohibits the Securities and Exchange Commission (SEC or Commission) from seeking civil penalties in certain enforcement...more

Federal District Court Finds Private-Insurer Relator Can Proceed with False Claims Action

Last month, the U.S. District Court for the District of New Jersey held that a private company, Allstate Insurance Company, could proceed with its whistleblower action against a clinical laboratory, Phoenix Toxicology and Lab...more

Disruptive Technology Strike Force Announces Its First Declination to Prosecute Under the National Security Division’s Voluntary...

On May 22, 2024, the Department of Justice’s National Security Division (“NSD”) announced its first declination of prosecution for a company under the voluntary self-disclosure program established by the National Security...more

BIS Continues Enforcement Policy Ramp-Up

On January 16, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to incentivize voluntary self-disclosure (“VSD”) of possible violations of the Export Administration...more

Education Department Delays Sept. 1 Effective Date of Dear Colleague Letter on Third-Party Servicers

On April 11, 2023, the U.S. Department of Education announced in a blog post that it will delay the Sept. 1, 2023, effective date of its Dear Colleague Letter on third-party servicers and institutions (DCL). The new effective...more

Department of Education Guidance Expands Possible Liability for Private Companies That Contract With Higher Education Institutions

On Feb. 15, 2023, the U.S. Department of Education issued guidance that significantly expands the definition of “third-party servicer” to include services completed by many online program managers (OPMs) and entities...more

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