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Constitutional Challenges Administrative Law Judge (ALJ)

Fisher Phillips

Agency Judges’ Power at Risk Again: Family Farm Fights Back After DOL Demands $500K for Alleged H-2A Program Violations

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A federal appeals court will soon decide whether the Department of Labor (DOL) may impose financial penalties on employers for alleged violations of the H-2A temporary visa program. While a lower court rejected a family-owned...more

McDermott Will & Emery

Federal Court Strikes Down LDT Final Rule

On March 31, 2025, the US District Court for the Eastern District of Texas struck down the US Food and Drug Administration’s (FDA) final rule under which FDA would have started regulating most laboratory-developed tests...more

Mayer Brown

Brasília em Pauta – Edição Nº 193

Mayer Brown on

O “Brasília em Pauta” é um boletim semanal preparado pela equipe de Contencioso de Brasília, contendo os principais casos a serem julgados pelo Supremo Tribunal Federal (STF), Superior Tribunal de Justiça (STJ) e Tribunal de...more

Cranfill Sumner LLP

United States Supreme Court Upholds Biden Administration’s Regulation of Ghost Guns

Cranfill Sumner LLP on

In November 2023 we discussed the Fifth Circuit Court of Appeals’ decision to strike down a Biden-era firearm regulation concerning “ghost guns,” concluding that the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF)...more

McAfee & Taft

Gavel to Gavel: Warrants and the workplace

McAfee & Taft on

Law enforcement agents are not all-powerful in the United States; their power is restricted by the Fourth Amendment to the United States Constitution. Although primetime police dramas often paper over the details, every...more

Frost Brown Todd

Sick of ALJs? The New Right to Federal Court During Agency Prosecutions

Frost Brown Todd on

Practitioners and scholars all agree that last summer, the U.S. Supreme Court overhauled the administrative state. And no, not simply by overturning Chevron, which was undoubtably the most significant decision of the Supreme...more

Snell & Wilmer

FDIC Reverses Position on the Constitutionality of In-House Administrative Law Judges

Snell & Wilmer on

After several Supreme Court decisions and Executive Orders upended many of the norms governing the relationship between governmental agencies and the constitutional branches, a recent decision by the Federal Deposit Insurance...more

Orrick, Herrington & Sutcliffe LLP

District court dismisses bank’s constitutional challenge to FDIC administrative proceedings

On March 3, the U.S. District Court for the District of Kansas dismissed a constitutional challenge to enforcement proceedings by the FDIC, ruling the court lacked subject matter jurisdiction over the plaintiff’s claims. As...more

Holland & Knight LLP

DOJ Forsakes Defending the ALJ Process Against Article II Challenges

Holland & Knight LLP on

On Feb. 18, 2025, in a case seeking declaratory and injunctive relief against the SEC, the U.S. Department of Justice (DOJ) filed a Notice of Change in Position indicating that the DOJ will no longer defend in litigation "the...more

Orrick, Herrington & Sutcliffe LLP

FDIC declines to defend administrative law judges in bank litigation, bank responds

On February 24, the FDIC informed the U.S. District Court for the District of Kansas that it would no longer defend its use of administrative law judges (ALJs). As previously covered by InfoBytes, DOJ declared the multiple...more

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

Proskauer Rose LLP

Axed ALJ Removal Protections Mark Big Shift For NLRB

Proskauer Rose LLP on

The continued legal challenges to the constitutionality of certain aspects of the National Labor Relations Board and the National Labor Relations Act took a potentially significant turn in a decision issued by the U.S....more

Proskauer - Labor Relations Update

Breaking: NLRB Drops Opposition to SpaceX’s Constitutionality Arguments

On February 3, 2025, the National Labor Relations Board (“NLRB” or the “Board”) filed a letter with the U.S. Court of Appeals for the Fifth Circuit on Space Exploration Technologies Corp. v. NLRB, Consolidated Case No....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

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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

Hogan Lovells

Constitutional challenges facing FTC may find receptive audience in nominee to lead the Commission

Hogan Lovells on

The Federal Trade Commission (FTC) is currently facing a growing number of challenges related to the constitutionality of the agency’s structure and operation. One of these challenges was raised by current FTC...more

Benesch

Changes at Every Level: Board Announces New Standard for Employer Unilateral Change, Federal Judge Rules that NLRB Administrative...

Benesch on

On Tuesday, December 10, 2024, the National Labor Relations Board (“NLRB”) made it more difficult for employers to make changes to their employees’ working conditions without approval from their union. ...more

Genova Burns LLC

NLRB ALJs’ Job Protections in Jeopardy After District Court Ruling

Genova Burns LLC on

On December 10, 2024, U.S. District Court Judge Trevor McFadden, sitting in the District of Columbia, ruled that the job protections afforded NLRB Administrative Law Judges (ALJs) are unconstitutional because they impede the...more

Orrick, Herrington & Sutcliffe LLP

State chartered bank challenges constitutionality of FDIC enforcement proceedings

On November 19, a Kansas state chartered bank filed a complaint for declaratory and injunctive relief against the FDIC and two Administrative Law Judges (ALJs) from the Office of Financial Institution Adjudication. The...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

Morgan Lewis

DC Circuit Sidesteps Questions Around FINRA’s Constitutionality

Morgan Lewis on

On November 22, 2024, the US Court of Appeals for the DC Circuit issued its decision in the closely watched Alpine Securities Corp. v. FINRA case. Declining to decide larger constitutional questions, the court instead...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

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