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Administrative Proceedings

Venable LLP

Supreme Court to Decide Whether Jarkesy Jury-Trial Right Extends to Federal Communications Commission Monetary Penalties

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The Supreme Court has agreed to resolve a circuit split on whether the Seventh Amendment's jury-trial guarantee and Article III permit a statutory scheme that allows the Federal Communications Commission (FCC) to impose...more

Cooley LLP

SEC in the Courts: SCOTUS to Review Disgorgement Powers (Again), District Court Upholds Follow-On Administrative Proceedings

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2026 is off to a rousing start for the US Securities and Exchange Commission (SEC), with two notable developments related to the agency’s civil enforcement authority....more

Venable LLP

Federal Court Upholds SEC's Ability to Pursue Industry Bars in Administrative "Follow-On" Proceedings After Jarkesy

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The U.S. District Court for the District of Columbia confirmed that a recent Supreme Court decision limiting the Securities and Exchange Commission's (SEC) use of its administrative forum—SEC v. Jarkesy—did not eliminate the...more

Foley & Lardner LLP

SEC Administrative Courts Survive Industry Ban Challenge

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For years, there have been efforts to chip away at the Securities and Exchange Commission’s (SEC) administrative enforcement powers. In particular, in 2024, the Supreme Court ruled in SEC v. Jarkesy, 603 U.S. 109 (2024), that...more

Marshall Dennehey

Legal Update for Special Education Law – Case Law Update - January 2026

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Court Upholds Hearing Officer’s Decision and Grants Full Attorneys’ Fees After School Misses IDEA Appeal Deadline - A.L.L., A.L. v. Laboratory Charter School, 2025 WL 3269941 (E.D. Pa. Nov. 24, 2025) - The parent, A.L., filed...more

Jackson Lewis P.C.

Double Trouble for Employers? Puerto Rico Supreme Court Finds PR OPM Can Bring Dual Proceedings for Sex, Pregnancy Discrimination

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The Women’s Advocate Office (“OPM,” for its Spanish acronym) has the authority to investigate and fine public and private employers that violate women’s rights under Puerto Rico constitution and laws, including employment...more

Orrick, Herrington & Sutcliffe LLP

FDIC publishes November 2025 enforcement actions

Recently, the FDIC published its list of administrative enforcement actions issued in November 2025. The agency reported seven orders and stated one of those orders had previously been “inadvertently omitted.” ...more

McDermott Will & Schulte

USPTO elevates precedential and informative decisions on discretionary institution in IPR/PGR

The United States Patent and Trademark Office (USPTO) designated four decisions as precedential and nine decisions as informative, all highlighting the factors the USPTO will consider in determining whether to deny a petition...more

Carlton Fields

The Show Goes On: SEC Gag Orders Survive Constitutional Challenge

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For more than five decades, the SEC’s “no admit, no deny” (NAND) settlement policy has served as an important script for its enforcement program. Under Rule 202.5(e) of the SEC’s Rules of Practice, defendants and respondents...more

Parker Poe Adams & Bernstein LLP

SEC May Ban Defendants From the Securities Industry Despite Supreme Court's Jarkesy Precedent

The U.S. District Court for the District of Columbia on January 8, 2026, rejected arguments by two former investment advisers that they could be permanently banned from the securities industry only after a jury trial....more

Herbert Smith Freehills Kramer

The US Supreme Court To Resolve Circuit Disputes On Administrative Enforcement Powers

On January 9, 2026, the Supreme Court granted certiorari in three cases to resolve disputes regarding the scope of administrative enforcement powers by the Securities and Exchange Commission and the Federal Communications...more

Orrick, Herrington & Sutcliffe LLP

D.C. District Court dismisses challenges to SEC ‘follow-on’ industry ban

On January 8, the U.S. District Court for the District of Columbia granted the SEC’s motion to dismiss a constitutional challenge to its follow-on administrative proceeding brought by two California-based investment advisers....more

BakerHostetler

All Hat, No Cowboy: What’s Next for the FTC After Corpay’s Fuel Card Rodeo Gets Enjoined?

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On Jan. 7, the Eleventh Circuit rode tall in the saddle, unanimously affirming, almost in full, a district court’s decision on summary judgment against Corpay (a corporate payments company formerly known as FleetCor) and...more

DLA Piper

SEC Industry Bars Post-Jarkesy

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United States District Judge Christopher Cooper has rejected a post-Jarkesy challenge to the US Securities and Exchange Commission’s (SEC) authority to impose industry bars through administrative proceedings. In Michael...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

USPTO Designates as Precedential or Informative Fifteen AIA Decisions on Discretionary Institution Considerations

On January 9, 2026, the USPTO designated four decisions as precedential and nine decisions as informative. And soon after, on January 12, 2026, the USPTO designated one more decision as precedential and another as...more

Freeman Mathis & Gary

Q4 – 2025 FMG Professional Liability Quarterly Report

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A summary of the important professional liability topics by our expert team members for the fourth quarter. When the Supreme Court decided Sec. & Exch. Comm’n v. Jarkesy, 603 U.S. 109 (2024) last summer —holding that the...more

Troutman Pepper Locke

Justices’ Separation-Of-Powers Revamp May Hit States Next

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Trump v. Slaughter, argued before the U.S. Supreme Court in December, likely will put an end to the era of independent federal regulatory agencies. Even if the court does not formally overrule the 90-year-old precedent...more

Nelson Mullins Riley & Scarborough LLP

FTC Administrative Action Delayed as Dealer Group Presses for Reconsideration of Order Denying Constitutional Challenge

After a delay caused by the shutdown of the federal government last fall, Asbury Automotive Group (“Asbury”), one of the largest automobile dealer groups in the country, has resumed its constitutional challenge to the...more

Troutman Pepper Locke

Pruitt v. NCAA: A Bellwether Case on Due Process in NCAA and CSC Enforcement Models?

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The preliminary injunction issued by the Circuit Court of DeKalb County, Alabama blocking enforcement of the NCAA’s six-year show-cause penalty against former University of Tennessee head football coach Jeremy Pruitt...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

Reissue, Reexamination, and Supplemental Examination Strategies and Insights – December 2025

In the mid-2000s, the U.S. Patent Office (USPTO) determined that reexaminations would be more consistent and legally correct if performed by a centralized set of experienced and specially trained Examiners....more

Holtzman Vogel Baran Torchinsky & Josefiak

Former New York Governor Sues State Ethics Panel

In a lawsuit filed in Albany County Supreme Court, former New York State Governor Andrew Cuomo is challenging the ability of the state Commission on Ethics and Lobbying in Government (COELIG) to pursue ethics charges against...more

A&O Shearman

CFTC Announces Reforms To Rules Of Practice And Investigations

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On December 1, 2025, the Commodity Futures Trading Commission ("CFTC" or "the Commission") announced amendments to its Rules of Practice and Rules Relating to Investigations, which will affect how enforcement matters are...more

Proskauer - Labor Relations Update

No Injunction for You: Third Circuit Rejects Employer Bid to Halt NLRB Case, Setting up Circuit Split

In a significant decision, the Third Circuit Court of Appeals held on December 3, 2025 that federal courts lack jurisdiction to issue injunctions that would halt ongoing National Labor Relations Board (“NLRB”) administrative...more

Parker Poe Adams & Bernstein LLP

Fourth Circuit Limits Employee's Suit to Job Described in EEOC Charge

Prior to suing under Title VII or other federal civil rights laws, an aggrieved party must first file an administrative charge of discrimination with the Equal Employment Opportunity Commission. The charge must contain...more

Troutman Pepper Locke

Court Denies Injunction Seeking to Halt FERC Enforcement Proceedings

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On November 24, 2025, the U.S. District Court for the Middle District of North Carolina denied American Efficient LLC’s (American Efficient) preliminary injunction seeking to halt FERC’s civil enforcement proceedings for...more

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