Lucia: The Beginning of the End of SEC ALJ?

by Dorsey & Whitney LLP

The Supreme Court resolved the question of whether SEC ALJs must be appointed in accord with the Constitution’s Appointments Clause, holding that their retention is subject to the provision. Thus the Court held that Petitioner Raymond J. Lucia is entitled to a new hearing before a different ALJ appointed in accord with the Constitution. Raymond J. Lucia, vs. Securities and Exchange Commission, No. 17-130 (June 21, 2018). The Court’s ruling leaves unresolved, however, more issues that it resolved concerning the constitutionality of ALJs, the appropriate remedies for a violation of the Clause and ultimately the question which sparked the controversy that resulted in the case – venue selection for SEC enforcement actions.

The Court’s opinion

The Court’s ruling is a straight forward application of Frytag v. Commissioner, 501 U.S. 869 (1991). The Constitution’s Appointments Clause, Article II, §2, Cl. 2, provides that only the President, a court of law, or a head of department can appoint Officers of the United States. The question considered by the Court is whether SEC ALJs are Officers within the meaning of the clause. Those who are must be appointed in accord with the Clause, here by the SEC since it is considered a department head for this purpose.

Two prior decisions by the Court provided the guideposts to resolving this question, according to the opinion authored by Justice Kagan and joined by six other Justices. First, in U.S. v. Germaine, 99 U.S. 508 (1879) the Court found that civil surgeons – doctors retained to perform certain exams – held “temporary rather than continuing and permanent” positions. The position must be established by law. Temporary positions were deemed not sufficient.

Second, Buckley v. Valeo, 424 U.S. 1 (1976)(per curiam) held that members of a federal commission were Officers within the meaning of the Clause after concluding that they exercised “significant authority” under the laws of the United States. While the “significant authority” test requires an analysis of the powers exercised by the person and may need refinement as urged by amicus who defended the decision below following the confession of error by the Solicitor General who joined with Petitioner in challenging the ALJ appointment here, that is not required now, according to the Court. This is because in Frytag “we applied the unadorned ‘significant authority’ test to adjudicative officials who are near-carbon copies of the Commission’s ALJs.” Frytag “says everything necessary to decide this case.”

Frytag considered whether special trial judges at the Tax Court were Officials under the Clause. The authority of those judges was a function of the matter before them. In major matters they would preside over the hearing and prepare findings and an opinion for a regular Tax Court judge. The STJs could not issue the final ruling. For other matters the STJs could issue a final ruling.

The case in Frytag involved a major matter. The Court held that the STJs were in fact Officers for purposes of the Appointments Clause. The ruling is based on two key considerations. First, citing Germaine, the Court found that the positions were established by law and permanent. Second, following Buckley the Court concluded that the position requires the exercise of significant authority. This is because STJs were required to take testimony, conduct trials, rule on the admissibility of evidence and enforce compliance with discovery orders. Carrying out these obligations requires the exercise of significant authority. The fact that in the major case before the Court the STJ could not enter the final decision was not dispositive. Rather, the Court found that STJs were Officers under the Appointments Clause. Since it is undisputed that SEC ALJs have virtually identical authority, they are Officers and must be appointed in accord with the Clause. While there are some differences between the authority of an SEC ALJ and a STJ as amicus argued, they are not significant and do not detract from the conclusion that Frytag resolves this case.

The appropriate remedy for “an adjudication tainted with an appointments violation is a new ‘hearing before a properly appointed’ official,” the Court concluded. In this regard the Court held that the SEC ALJ who presided over the initial hearing cannot conduct the new proceeding even if properly appointed. This is because the remedies in these cases are designed in pat to create incentives for persons to present these challenges and those are aided by directing that a different, properly appointed official, preside at the new hearing. Accordingly, to “cure the constitutional error, another ALJ (or the Commission itself) must hold the new hearing to which Lucia is entitled.” The Court declined to consider the validity of the SEC’s November 30, 2017 order that sought to “ratify” the appointment of its ALJs.

Justice Thomas, joined by Justice Gorsuch, concurred. In his opinion the Justice noted that the Court’s opinion dissusses what is “sufficient to make someone an officer of the United States, [but] our precedents have never clearly defined what is necessary.” (emphasis original). “To the Founders, this term [Officer] encompassed all federal civil officials with responsibility for an ongoing statutory duty.” (Internal citations omitted). Viewed in this context SEC ALJs “easily qualify as ‘Officers of the United States’ . . . the importance or significance of their statutory duties is irrevelant.”

Justice Breyer, concurred in the judgment but dissented in part in an opinion joined by Justices Ginsburg and Sotomayor. While Justice Breyer agrees that that the SEC did not properly appoint its ALJs, the case should have been resolved on statutory grounds and the constitutional issue avoided since its resolution was unnecessary.

This case could be resolved by considering the dictates of the Administrative Procedure Act or APA. That statute, enacted in 1946, provided in part that each agency could retain as many Administrative Law Judges as necessary for hearings governed by the Act. That Act does not provide that the Commission can simply delegate its power to appoint its administrative law judges to the staff. The APA requires a published order or rule for delegation. Here the SEC did not publish such an order or rule. Its effort to delegated the authority to hire ALJs to its staff is thus invalid.

A second reason for not resolving the question here stems from the Court’s prior ruling in Free Enterprise Fund v. Public Company Accounting Oversight Board, 561 U.S. 477 (2010). That case considered the statutory provisions protecting members of the PCAOB from removal without cause. There the “Court held . . .that the Executive Vesting Clause of the Constitution, Art. II, §1 (‘[t]he executive Power shall be vested in the President of the United States of America’), forbade Congress from providing members of the board with ‘multilevel protections from removal’ by the President,” quoting Free Enterprise Fund, 561 U.S. at 484. This is because Congress cannot limit the authority of the President by providing two levels of employment protection. In resolving this question the Court stated that members of the Board are Officers of the United States, although the “significance of that fact to the Court’s analysis is not entirely clear,” according to Justice Breyer.

The APA also provides protections from removal for ALJs. Those provisions were viewed as important parts of the APA since they provided them with insulation from the political processes. This is because prior to the Act, hearing officers were subject to their agency which created issues regarding their independence.

“If the Free Enterprise Fund Court’s holding applies equally to the administrative law judges – and I stress the ‘if’ – then to hold that the administrative law judges are ‘Officers of the United States’ is, perhaps, to hold that their removal protections are unconstitutional. This would risk transforming administrative law judges from independent adjudicators into dependent decision makers, serving at the pleasure of the Commission.” (emphasis original). At the same time the Court in Free Enterprise “disagreed [with my dissent stating this point] saying that ‘none of the positions” such as ALJs identified in the dissent are “similarly situated to the Board.”

Viewed in this context, a holding that ALJs are Officers could come into conflict with the Free Enterprise Fund’s limitation on the “for cause” protections from removal. In that event the decision of Congress to provide those protections would be called into question. Yet under the Appointments Clause Congress’ intent is important. Its determination on this point would suggest that in fact SEC ALJs are not Officers as the Court ruled. It is because of these issues that the Solicitor General urged the Court to consider this question. The Court declined.

Finally, there is no reason that the new hearing ordered in this case has to be presided over by a different ALJ, according to Justice Breyer.

Justice Sotomayor dissented in an opinion joined by Justice Ginsburg. The Court’s jurisprudence in this area offers little guidance, the Justice noted. “To provide guidance to Congress and the Executive Branch, I would hold that one requisite component of ‘significant authority’ is the ability to make final, binding decisions on behalf of the Government. Accordingly, a person who merely addresses and provides recommendations to an officer would not herself qualify as an officer.” While SEC ALJs have “extensive powers,” “I would hold that Commission ALJs are not officers because they lack final decision making authority.” In addition, “I share Justice Breyer’s concerns regarding the Court’s choice of remedy. . .”


Lucia resolves the one question the Court agreed to hear in granting certiorari. It leaves unresolved, however, more questions than it actually resolves, ultimately casting a pall of uncertainty over the Commission’s administrative hearing process that undoubtedly will spawn more litigation. It could be years before the ultimate validity of SEC ALJ’s is resolved.

To be sure, the Court did in fact resolve the question of whether the Commission’s ALJs must be appointed in accord with the dictates of the Constitution’s Appointments Clause. SEC ALJs are in fact Officers within the meaning of the Appointments Clause the Court concluded. Therefore they must be appointed by the Commission. If there was any doubt that simply directing the staff to hire the ALJs is not permissible, Justice Breyer’s opinion puts the question to rest. Indeed, that procedure seems to undercut the very purpose of the APA as detailed by the Justice which, in part was to try and separate and insulate the hearing process to help ensure fairness. Permitting the staff to select the ALJs while having the staff prosecute the hearings over which they preside is more than the appearance of unfairness in a system already tinged with questions about due process.

In resolving the Appointments Clause question the Court refused to consider the related question presented by the Solicitor General and Justice Breyer regarding the employment protections afforded SEC ALJs under the APA in view of Free Enterprise Fund. As Justice Breyer points out, Free Enterprise Fund at least suggests that PCAOB members are in fact Appointment Clause Officers, although that determination was not crucial to the holding of that decision. If in fact that suggestion is correct then it would indicate that the APA employment protections afforded to SEC ALJs are contrary to the dictates of the Constitution’s vesting clause. That suggestion, however, is at odds with the statement in Free Enterprise Fund that its holding does not impact ALJs. At the same time, the fact that Congress provided those protections to ALJs seems to undercut the Court’s conclusion in Lucia as well as Freytag. It was to avoid this difficulty that the Solicitor General, as well as Justice Breyer and those who joined his opinion, urged the Court to consider the question along with the Appointments Clause issue.

The Court also specified the remedy for Petitioner. That question received no attention in the lower court and little in the briefing process. In doing so it sidestepped the question of ratification presented by the SEC’s November 2017 order. Whether that process constitutes a proper remedy for what has been held to be a clear constitutional error is thus an open question.

Finally, the critical question which launched Lucia and a host of other similar cases is not even mentioned – venue. It was the Commission’s decision to largely move its enforcement actions “in-house” rather than filing cases in federal district court which spawned Lucia and a number of other cases challenging those decisions. Thus, while Mr. Lucia and his firm “won” in terms of the case, after years of litigation they are no closer to their actual goal. It is perhaps the ultimate irony of the case that while Petitioners sought to escape a hearing in front of an administrative law judge by “winning” they now have the right to a new hearing before another administrative law judge.

Viewed in the context Lucia presents the ultimate “ground hog day” experience – an opportunity to go round and round to nowhere. The venue selection issue which launched Lucia has not been addressed. And, while the one issue about the Appointments Clause has been resolved, as Justice Breyer points out there are other significant questions waiting resolution. As Justice Bryer pointed out: “By considering each question in isolation, the Court risks . . . unraveling, step-by-step, the foundations of the Federal Government’s administrative adjudication system as it has existed for decades, and perhaps of the merit-based civil-service system in general. And the Court risks doing so without considering the potential consequences.” If the Commission wants to avoid the prospect it could reconsider its approach to venue selection. The agency also could consider soliciting comments from those given a Wells notice regarding venue. Absent some remedy all of its future administrative proceedings could be tainted, ultimately bringing about Justice Breyer’s prediction.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Dorsey & Whitney LLP | Attorney Advertising

Written by:

Dorsey & Whitney LLP

Dorsey & Whitney LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.