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Non-Delegation Doctrine

Venable LLP

Rethinking Independent Agencies: Forthcoming Supreme Court Decision on Firing of FTC Commissioner May Have Far-Reaching...

Venable LLP on

Independent agencies have long been a key part of the federal administrative state. Today, they effectively govern wide swaths of the economy—enforcing antitrust laws, regulating securities markets, and managing interstate...more

Womble Bond Dickinson

Tariffs on Trial: The IEEPA Challenge and the Future of Executive Trade Authority

Womble Bond Dickinson on

The Supreme Court’s pending review of President Trump’s use of the International Emergency Economic Powers Act (IEEPA) to impose broad-based import tariffs is not merely a fight over one tariff schedule. It is a stress test...more

Orrick, Herrington & Sutcliffe LLP

Ninth Circuit upholds FHFA funding structure against constitutional challenge

On January 2, the U.S. Court of Appeals for the Ninth Circuit upheld the constitutionality of the FHFA’s funding mechanism, affirming the dismissal of a lawsuit that challenged the agency’s authority under the Appropriations...more

Epstein Becker & Green

A Pattern of Uncertainty: Judicial Decision-Making During Federal Shutdowns

In the wake of this country’s longest federal shutdown, federal courts were facing unprecedented decision-making whether to stay civil proceedings implicating federal employees and agencies....more

Parker Poe Adams & Bernstein LLP

New Lawsuit Takes Aim at Constitutionality of OSH Act

In 2023, the Sixth Circuit Court of Appeals rejected arguments challenging the constitutionality of the Occupational Health and Safety Act. The suit alleged that the 1970’s law violates separation of powers principles because...more

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

OSHA’s Nondelegation Challenge: Stakes and Arguments

On December 3, 2025, the Texas International Produce Association and the Texas Vegetable Association filed suit in the U.S. District Court for the Northern District of Texas, Amarillo Division, seeking declaratory and...more

Akin Gump Strauss Hauer & Feld LLP

Previewing Appellate Arguments on Whether the False Claims Act’s Qui Tam Provisions Are Constitutional and, If Not, the Remedy:...

Recently, three Supreme Court Justices, unsolicited, invited inquiry into the constitutionality of the False Claims Act’s (FCA) qui tam provisions. This inquiry has vast significance. The FCA is the government’s chief weapon...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Regional Haze/Advance Notice of Proposed Rulemaking: Arkansas and 17 other State Attorney Generals' Comments on EPA's Solicitation...

The State of Arkansas and 17 other Attorney Generals filed December 1st Comments addressing an October 2nd Advanced Notice of Proposed Rulemaking (“ANPR”) issued by EPA styled: Visibility Protection: Regional Haze State...more

Morgan Lewis

In OSH Act Constitutionality Challenge, Texas Produce Groups Try Their Luck in Fifth Circuit

Morgan Lewis on

The challenge to the OSH Act by two produce associations has the potential to reshape the future of workplace safety regulation and again test the outer limits of congressional delegation to administrative agencies....more

Foley & Lardner LLP

What Every Multinational Should Know About … Preserving the Right to IEEPA Tariff Refunds

Foley & Lardner LLP on

Any company that has imported goods subject to the Trump administration’s fentanyl-based tariffs or reciprocal tariffs — i.e., the tariffs levied pursuant to the International Emergency Economic Powers Act (the IEEPA tariffs)...more

Parker Poe Adams & Bernstein LLP

Cato Urges Supreme Court Review of SEC Disgorgement Authority Dispute

The Cato Institute filed an amicus brief this month urging the U.S. Supreme Court to resolve a growing split among the United States circuit courts of appeals concerning the Securities and Exchange Commission’s authority to...more

ArentFox Schiff

How the Supreme Court’s IEEPA Ruling Could Recast US Tariffs

ArentFox Schiff on

The US Supreme Court has fast-tracked challenges to President Trump’s unprecedented use of the International Emergency Economic Powers Act (IEEPA) to impose wide‑ranging tariffs, and based on recent oral argument, it is...more

Beveridge & Diamond PC

Are Extended Producer Responsibility Laws Constitutional: A Look at the Legal Challenge in Oregon

Beveridge & Diamond PC on

Key Takeaways - Many states have now enacted extended producer responsibility (EPR) laws, creating new and costly requirements for manufacturers, wholesalers, and retailers based on the packaging of the products they...more

A&O Shearman

Fifth Circuit Judge Renews Scrutiny Of FCA’s Qui Tam Constitutionality

A&O Shearman on

On November 3, 2025, the United States Court of Appeals for the Fifth Circuit affirmed the dismissal with prejudice of an action under the False Claims Act (“FCA”) against an inpatient-rehabilitation facility. See United...more

ArentFox Schiff

Investigations Newsletter: Fifth Circuit Judge Questions Constitutionality of the FCA’s Qui Tam Provision

ArentFox Schiff on

Fifth Circuit Judge Questions Constitutionality of the FCA’s Qui Tam Provision - The Fifth Circuit affirmed the dismissal of a lawsuit brought under the False Claims Act (FCA) by a relator for failure to state a claim and...more

Brownstein Hyatt Farber Schreck

Supreme Court Hears Oral Argument in Consolidated Challenges to IEEPA Tariffs

On Nov. 5, the Supreme Court heard oral arguments to consider the legality of two separate challenges to the president’s use of the International Emergency Economic Powers Act (“IEEPA”) to impose tariffs in the consolidated...more

Clark Hill PLC

Supreme Court Hears IEEPA Tariff Challenge: A Test of Presidential Power

Clark Hill PLC on

On November 5, 2025, the Supreme Court heard three hours of oral argument in the most consequential trade case in years, a challenge to the President’s use of the International Emergency Economic Powers Act (IEEPA) to impose...more

Orrick, Herrington & Sutcliffe LLP

What the Supreme Court Oral Arguments Mean for Tariff Payers and Tariff Refund Claim Buyers

The Supreme Court has heard oral argument in a case to determine whether the Trump administration’s sweeping tariff regime, imposed under the International Emergency Economic Powers Act (IEEPA), is lawful. ...more

Kelley Drye & Warren LLP

Supreme Court Hears Oral Arguments in Trump v. V.O.S. Selections, Inc. and Learning Resources, Inc. v. Trump Concerning...

On November 5, 2025, the U.S. Supreme Court heard oral arguments in the consolidated case of Trump v. V.O.S. Selections, Inc. and Learning Resources, Inc. v. Trump. This case is about presidential power. Specifically, the...more

Vinson & Elkins LLP

Breakdown of Supreme Court Oral Argument in the Tariff Cases and What Importers Should Be Prepared For, No Matter the Outcome

Vinson & Elkins LLP on

The Supreme Court held a marathon, nearly 3-hour oral argument yesterday, in what could be the most economically-impactful cases this Term: Learning Resources, Inc. v. Trump and Trump v. V.O.S. Selections (the “Tariff...more

Adams & Reese

As Trump's IEEPA Tariffs Head to SCOTUS, Importers Should Start Preserving Refund Rights

Adams & Reese on

The Federal Circuit Court of Appeals affirmed the Court of International Trade’s decision that the tariffs imposed by President Trump under the International Emergency Economic Powers Act (IEEPA) are unlawful. This week, the...more

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

OSHA and OSHRC in Transition, Part II: Contemporary Challenges, Litigation Posture, and Prospective Reforms

Today’s constitutional challenges to the Occupational Safety and Health Administration (OSHA) and the Occupational Safety and Health Review Commission (OSHRC) converge on three fronts: Article II of the U.S. Constitution...more

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

OSHA and OSHRC in Transition, Part I: Early and Evolving Constitutional Challenges

The Occupational Safety and Health Administration (OSHA) and the Occupational Safety and Health Review Commission (OSHRC) emerged from the Occupational Safety and Health Act of 1970 to address widespread concerns about...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - October 2025 - Unconstitutionality of IEEPA Tariffs Upheld – Supreme Court to Review

The Court of Appeals for the Federal Circuit (CAFC) sitting en banc (11 active judges participating) affirmed, in a 7-4 majority decision filed on August 29, 2025, the decision of the U.S. Court of International Trade (CIT)...more

McCarter & English, LLP

Losing on Trade, Trump Sows Chaos by Imposing $100,000 “Tariff” on H-1B Employers

This administration’s effort to usurp Congressional authority pivoted from trade to immigration policy late Friday, September 19, 2025. The President issued a presidential proclamation restricting the entry of any H-1B...more

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