News & Analysis as of

Securities and Exchange Commission (SEC) Article II Administrative Proceedings

Hogan Lovells

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

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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

Venable LLP

Jarkesy: SEC Change-Up - The Supreme Court Curbs the Use of Administrative Courts for Litigated Fraud Claims and Civil Penalties

Venable LLP on

In a landmark decision issued last week, SEC v. Jarkesy, the Supreme Court held that the Seventh Amendment guarantees a defendant a jury trial when the SEC seeks civil penalties against the defendant for committing securities...more

Axinn, Veltrop & Harkrider LLP

In SEC v. Jarkesy, Supreme Court Leaves Open Constitutional Challenges Related to FTC Structure and Process

In a much-watched case concerning the administrative state, on June 27, the Supreme Court decided in SEC v. Jarkesy that defendants facing a fraud suit by the SEC have a Seventh Amendment right to a jury trial in an Article...more

Fisher Phillips

SCOTUS Predictions: Supreme Court Set to Limit Labor Board’s Reach Over Employers in Surprising Way

Fisher Phillips on

An impending Supreme Court decision is poised to transform how the National Labor Relations Board decides cases and may fundamentally alter the course of labor relations as we know it. We predict that a SCOTUS decision to be...more

Ballard Spahr LLP

SCOTUS to hear oral argument on Nov. 29 in case involving challenge to use of administrative law judges by federal agencies

Ballard Spahr LLP on

On November 29, 2023, the U.S. Supreme Court will hear oral argument in Jarkesy v. Securities and Exchange Commission, a case in which the respondents are challenging the constitutionality of the SEC’s use of administrative...more

Jackson Walker

White Collar Docket Check: US Supreme Court to Decide Key Administrative, Whistleblower, and Due Process Cases This Term

Jackson Walker on

The U.S. Supreme Court began its new term this week and is taking cases government enforcement practitioners will want to follow. Specifically, the Court will address issues concerning: the interplay between SEC...more

Robinson & Cole LLP

Fifth Circuit Decision Threatens to Upend SEC’s Use of Administrative Proceedings

Robinson & Cole LLP on

In a landmark decision, the Fifth Circuit struck down the U.S. Securities and Exchange Commission’s (SEC) primary mechanism for enforcing the nation’s securities laws. In Jarkesy v. Securities and Exchange Commission, a...more

Jenner & Block

Fifth Circuit Holds SEC's In-House Forum is Unconstitutional

Jenner & Block on

When Congress passed the Dodd-Frank Act, it expanded the SEC’s power to use its in-house administrative forum to bring enforcement actions. Supporters said this change promoted investor protection by giving the SEC a more...more

Skadden, Arps, Slate, Meagher & Flom LLP

Fifth Circuit Holds SEC Proceeding Brought in Agency’s In-House Court Unconstitutional

Key Points On May 18, 2022, in Jarkesy v. SEC, No. 20-61007 (5th Cir. May 18, 2022), a split panel of the U.S. Court of Appeals for the Fifth Circuit identified three independent constitutional flaws in the administrative...more

Proskauer - Corporate Defense and Disputes

Fifth Circuit Holds SEC’s In-House Courts and Judges Unconstitutional

In Jarkesy v. Securities and Exchange Commission, the Court of Appeals for the Fifth Circuit issued a remarkable opinion holding numerous aspects of the SEC’s administrative enforcement regime are unconstitutional. The May...more

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

Supreme Court to Decide Who Can Appoint ALJs

The Supreme Court of the United States, on Friday, January 12, 2018, agreed to decide whether the former practice of the Securities and Exchange Commission (SEC) of having its chief judge appoint administrative law judges...more

Ballard Spahr LLP

DOJ sides with Lucia against the SEC in dispute over whether ALJs are inferior officers

Ballard Spahr LLP on

The Supreme Court is considering a cert petition requesting that it hear the Lucia case, which we have blogged about extensively due to its potential impact on the outcome of the PHH case. Significantly, the DOJ recently...more

K&L Gates LLP

SEC Reverses Course on ALJ Appointments Issue, but Uncertainty Remains

K&L Gates LLP on

On Thursday, November 30, 2017, the Securities and Exchange Commission (“SEC” or the “Commission”) took action to settle an issue that had been impacting its enforcement efforts for some time: whether its administrative law...more

Pillsbury Winthrop Shaw Pittman LLP

Circuit Split Cries Out for Supreme Court Review - Have SEC ALJs been operating contrary to the U.S. Constitution?

The District of Columbia Circuit Court of Appeals’ earlier decision in Lucia v. SEC that U.S. Securities and Exchange Commission (SEC) administrative law judges (ALJs) are employees who are not subject to the Appointments...more

K&L Gates LLP

D.C. Circuit Considers Reversal of Earlier Decision and May Declare SEC Administrative Law Judges Inferior Officers Subject to...

K&L Gates LLP on

On Wednesday, May 24, 2017, the U.S. Court of Appeals for the District of Columbia Circuit, sitting en banc, heard arguments in Raymond J. Lucia Cos. v. SEC, a case in which it is tasked with deciding whether the...more

Burr & Forman

SEC Stays ALJ Cases Subject to 10th Circuit Review

Burr & Forman on

On Monday, May 22, the SEC stayed all its administrative proceedings assigned to an ALJ in which a Respondent has an option for review by the 10th Circuit. (Securities laws provide appellate review of SEC administrative...more

Carlton Fields

Circuits Split Over Constitutionality of SEC’s Administrative Law Judges

Carlton Fields on

The Tenth Circuit Court of Appeals, in Bandimere v. SEC, recently held that the SEC’s administrative law judges (ALJs) are “inferior officers” whose appointments violate the Appointments Clause of the U.S. Constitution...more

Ballard Spahr LLP

Tenth Circuit ruling on constitutionality of SEC administrative judges: implications for CFPB

Ballard Spahr LLP on

Just before year-end, the U.S. Court of Appeals for the Tenth Circuit, in Bandimere v. United States Securities and Exchange Commission, set aside an SEC decision finding the petitioner liable for violating various securities...more

BCLP

Appellate Court Decision Casts New Doubts Regarding SEC Administrative Actions

BCLP on

A recent federal appellate decision casts new doubt on the SEC’s practice of using its own administrative law judges (ALJs) to hear actions brought by the SEC Enforcement Division. In a decision late last month, the U.S....more

Burr & Forman

Circuits Split - Tenth Holds SEC ALJs Unconstitutional

Burr & Forman on

The Tenth Circuit recently held that the SEC’s in-house judges are “inferior officers” hired in violation of Article II’s Appointment Clauses, creating a split with the D.C. Circuit over the issue. The Tenth Circuit held...more

Carlton Fields

D.C. Circuit: SEC’s In-House Court is Constitutional

Carlton Fields on

Previously, we advised that the Securities and Exchange Commission’s increased preference for bringing enforcement actions in its in-house court had triggered jurisdictional and constitutional challenges to SEC administrative...more

Brownstein Hyatt Farber Schreck

D.C. Circuit Upholds Constitutionality of SEC Administrative Law Judges

The Securities and Exchange Commission (“SEC”) scored a significant victory yesterday in its quest to defend the increased use of its in-house judges when a three-judge panel of the D.C. Circuit ruled that the appointment of...more

Ballard Spahr LLP

D.C Circuit rejects constitutional challenge to SEC’s use of administrative law judges

Ballard Spahr LLP on

A challenge to the constitutionality of the SEC’s use of administrative law judges (ALJ) was rejected by the U.S. Court of Appeals for the D.C. Circuit. In Raymond J. Lucia Companies, Inc. et al. v. Securities and Exchange...more

Burr & Forman

DC Circuit Upholds SEC ALJs in First Merits Opinion

Burr & Forman on

The D.C. Circuit has affirmed that SEC ALJs are not constitutional Officers subject to the Appointments Clause, rejecting perhaps the strongest of the constitutional challenges to the Commission’s administrative forum. The...more

Cadwalader, Wickersham & Taft LLP

The SEC Retains its House Advantage During Administrative Proceedings

Amendments to the Rules of Practice Do Little to Address Criticism that the Deck is Stacked - Facing pressure from industry practitioners and in the wake of constitutional challenges in multiple jurisdictions, the...more

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