News & Analysis as of

Administrative Law Judge (ALJ) SEC v Jarkesy

Ogletree, Deakins, Nash, Smoak & Stewart,...

New Challenges Loom for OSHA and OSHRC Amid Quorum Issues, Potential ALJ Removals, and Recent Supreme Court Jurisprudence

“The Times They Are a-Changin’” isn’t just a Bob Dylan song title—it is also a fairly accurate description of what has been happening in the arena of the Occupational Safety and Health Administration (OSHA) and the...more

Orrick, Herrington & Sutcliffe LLP

DOJ determines administrative law judges are unconstitutional

On February 20, Acting Solicitor General Sarah M. Harris wrote to Sen. Charles Grassley (R-IA), President pro tempore of the Senate, and Rep. Mike Johnson (R-LA), Speaker of the House, to disclose that, pursuant to 28 U.S.C....more

Carlton Fields

DOJ Withdraws Defense of SEC ALJs' Constitutionality as Trump Issues Executive Order on Agency Accountability

Carlton Fields on

On February 18, 2025, President Trump issued executive order 14215, titled “Ensuring Accountability for All Agencies,” with the stated purpose of making federal agencies, including independent regulatory ones like the...more

Mintz - Health Care Viewpoints

EnforceMintz —Could the Supreme Court’s Decision in Jarkesy Mean the End to HHS Civil Monetary Penalty Authorities as We Know...

Last June, the Supreme Court issued its decision in Securities and Exchange Commission v. Jarkesy, which holds that the Seventh Amendment entitles a defendant to a jury trial when the Securities and Exchange Commission (SEC)...more

Vinson & Elkins LLP

FERC Settles Decade-Old Enforcement Allegations

Vinson & Elkins LLP on

In 2016, a new play called Hamilton was dominating Broadway, Pokémon Go was all the rage, and the Summer Olympics were held in Rio. Also that year, the Federal Energy Regulatory Commission (“Commission” or “FERC”) issued an...more

Fisher Phillips

Top 2025 Predictions for Workplace Safety

Fisher Phillips on

Our Workplace Safety thought leaders have pulled together their top predictions for the new year so that employers can get a running start to 2025....more

Proskauer - Labor Relations Update

Federal District Court in D.C. Strikes Down Removal Protections for ALJs

The continued legal challenges to the constitutionality of certain aspects of the National Labor Relations Board (“NLRB”) and National Labor Relations Act (“NLRA”) took a potentially significant turn in a decision issued by...more

Holland & Knight LLP

The Nice List: Rounding Up Some Notable SCOTUS and Delaware Decisions in 2024

Holland & Knight LLP on

2024 brought several important decisions of the U.S. Supreme Court (SCOTUS) and the courts of the state of Delaware concerning how corporations, their boards of directors and officers interact with investors, regulators and...more

Jones Day

Court Rules DOL's ALJ Enforcement Scheme Likely Unconstitutional

Jones Day on

A government contractor challenged a U.S. Department of Labor ("DOL") Office of Federal Contract Compliance Programs ("OFCCP") enforcement scheme in federal court as violating the United States Constitution. The contractor...more

Constangy, Brooks, Smith & Prophete, LLP

Court halts OFCCP enforcement proceedings against contractor

The future of DOL’s administrative law judges is now murky. When the Office of Federal Contract Compliance Program believes that a contractor has violated affirmative action obligations, its tried-and-true practice for...more

Proskauer - Labor Relations Update

Amazon, SpaceX Must Navigate Procedural Roadblocks in Constitutional Challenge of NLRB

On November 18, 2024, the U.S. Court of Appeals for the Fifth Circuit heard oral argument on cases involving Amazon.com Inc. and SpaceX, respectively, challenging the constitutionality of the National Labor Relations Board...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Federal Court Ruling in Texas Challenges OSHA’s Administrative Law Judge System

In May 2023, in the wake of a ruling by the Supreme Court of the United States that U.S. district courts have jurisdiction to consider structural constitutional claims against administrative agencies, we predicted that the...more

Paul Hastings LLP

OFCCP Enforcement Action Against Federal Contractor Enjoined by U.S. District Court

Paul Hastings LLP on

Last week, the United States District Court for the Southern District of Texas entered a preliminary injunction barring the U.S. Department of Labor (DOL) from pursuing an enforcement action against a federal contractor, ABM...more

Proskauer - Government Contractor Compliance...

Texas District Court Issues Preliminary Injunction Halting OFCCP Administrative Proceeding

On October 30, 2024, the District Court for the Southern District of Texas preliminarily enjoined the Department of Labor (“DOL”), the Secretary of Labor, the Office of Federal Contract Compliance Programs (“OFCCP”), and the...more

Ballard Spahr LLP

Citing Jarkesy, Asbury Automotive Group files suit challenging FTC administrative proceeding

Ballard Spahr LLP on

One of the country’s largest automotive retailers filed suit against the Federal Trade Commission (“FTC”) on October 4, arguing that the Supreme Court’s recent landmark decision in Securities and Exchange Commission v....more

Genova Burns LLC

New Complaint Questions the Constitutionality of the Occupational Safety and Health Review Commission

Genova Burns LLC on

Kenric Steel, LLC, a New Jersey based steel fabrication company, filed a complaint in the U.S. District Court of New Jersey alleging that the Occupational Safety and Health Review Commission (OSHRC), an independent federal...more

Cooley LLP

Last term SCOTUS gave the administrative state quite a thumping. Does it still have the urge to curb?

Cooley LLP on

If you thought that SCOTUS’ decision in Loper Bright last term tolling the bell for the 70-year old Chevron doctrine was the end of SCOTUS’ drubbing of the administrative state, look again—you may well be sorely mistaken. You...more

Williams Mullen

The Supreme Court's Decision in SEC v. Jarkesy and Its Implications for EPA's Administrative Enforcement

Williams Mullen on

The Supreme Court's recent decision in SEC v. Jarkesy, 144 S. Ct. 2117, 219 L. Ed. 2d 650 (2024) marks a significant shift in the landscape of administrative enforcement, particularly concerning the power of federal agencies...more

Foley & Lardner LLP

FINRA In-House Disciplinary Proceedings Survive Post-Jarkesy Challenge … For Now

Foley & Lardner LLP on

On September 4, 2024, the United States District Court for the Eastern District of Pennsylvania denied D. Allen Blankenship’s challenge to enjoin the Financial Industry Regulatory Authority’s (FINRA) disciplinary action...more

Cranfill Sumner LLP

After Jarkesy, What Is Next for In-House Enforcement Proceedings?

Cranfill Sumner LLP on

Much virtual ink has been spilled in the weeks and months since the Supreme Court issued its opinion in Securities and Exchange Commission v. Jarkesy—much attesting to that the decision was the death knell for in-house...more

Orrick, Herrington & Sutcliffe LLP

Suit against FDIC argues the agency is “unconstitutional” and violates Jarkesy

Recently, the U.S. District Court for the District of Columbia received a complaint from an individual plaintiff suing the FDIC, its heads, board members and an administrative law judge (ALJ) for allegedly subjecting the...more

Ballard Spahr LLP

Defendant Challenges FDIC Enforcement Proceeding, Citing Jarkesy

Ballard Spahr LLP on

In one of the first tests of the implications of the Jarkesy decision for other federal regulatory agencies, an individual accused by the FDIC of participating in fraudulent loan activity is asking a federal judge to dismiss...more

Bradley Arant Boult Cummings LLP

Turning the Tables: Kroger Sues the FTC

In February of this year, the Federal Trade Commission (FTC) brought an administrative complaint to block Kroger Company’s $24.6 billion merger with Albertsons Companies, Inc., citing antitrust concerns. On August 19, 2024,...more

Orrick, Herrington & Sutcliffe LLP

Supreme Court Curtails Use of Administrative Courts in SEC Enforcement Proceedings: What it Means for Other Agencies and What...

The U.S. Supreme Court has ruled that defendants in securities fraud cases brought by the SEC are entitled by the Seventh Amendment to have the SEC’s claims for civil money penalties decided by a jury and not in an...more

Cadwalader, Wickersham & Taft LLP

Loper Bright, Jarkesy, and Implications for the SEC

“Chevron is overruled,” Chief Justice Roberts wrote in Loper Bright Enterprises v. Raimondo, because “[t]he deference that Chevron requires of courts reviewing agency action cannot be squared with the [Administrative...more

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