When Crafting Your Litigation Strategy, Keep These Trends in Mind
Recent trends in how federal district courts exercise their power of judicial review underscore the changing nature of regulatory litigation.
September 24, 2019 at 04:01 PM
6 minute read
The original version of this story was published on National Law Journal
Recent trends in how federal district courts exercise their power of judicial review underscore the changing nature of regulatory litigation. These trends start with the rise in multidistrict litigation, as groups of plaintiffs file complaints in multiple district courts to maximize their chances of blocking a federal policy. For their part, courts considering these challenges are exercising their power by refusing to defer to the executive branch and authorizing discovery. Individuals and businesses impacted by federal regulation should take these trends into consideration as they devise litigation strategies. (In the second installment of this two-part series, we will discuss two additional trends—the rigorous enforcement of the Administrative Procedure Act's standard of review and the rise of nationwide injunctions.)
Multidistrict litigation is booming.
The days when only a single judge would review a federal policy seem to be over with the explosion of multidistrict litigation.
Today, the government routinely faces multiple lawsuits across the country—from San Francisco to New York—as groups of plaintiffs file multiple challenges to federal policies. As but one example, district courts in California, New York, Washington, D.C., and Maryland each reviewed the Trump Administration's rescission of the Obama Administration policy known as Deferred Action for Childhood Arrivals.
For plaintiffs, multidistrict litigation provides multiple bites at the apple, increasing the likelihood that a court will enjoin the federal policy. By contrast, multidistrict litigation forces the government to run the table. And when a court enjoins a federal policy, the government must often seek extraordinary remedies—including from the U.S. Supreme Court—to defend the policy.
Expect this trend of multidistrict litigation to continue because the government often cannot channel multiple challenges into a single court.
Discovery is becoming the new norm.
Although discovery used to be rare in regulatory litigation, discovery is now increasingly common in challenges to government policies.
In regulatory litigation, courts typically review the agency's decision based exclusively on a record compiled by the agency. But the Supreme Court has allowed lower courts to look beyond the administrative record if there is a "strong showing of bad faith or improper behavior."
Until now, district courts rarely invoked this exception to allow plaintiffs to obtain discovery of the executive branch. But today, discovery orders (and related orders to supplement the administrative record) are increasingly common in high-profile cases. In the DACA cases, for example, the government sought mandamus from the Supreme Court to block extraordinary discovery orders.
The most recent example of discovery came in the census litigation involving the addition of a citizenship question. In Department of Commerce v. New York, the district court allowed extensive discovery and ordered the secretary of commerce to be deposed. Although the Supreme Court blocked the deposition, the Court upheld the district court's use of extra-record evidence.
Discovery often forces the government to take extraordinary steps to block discovery orders that risk disclosing privileged information. And those extraordinary efforts often force appellate courts to prejudge the merits of the case. Unless the Supreme Court provides definitive guidance, district courts seem inclined to continue ordering discovery in regulatory litigation, and the government will continue to seek extraordinary relief.
Deference is on the decline.
Courts are less likely to defer to the executive branch in two ways. First, courts have not been receptive to the government's argument that certain decisions are committed to the executive branch's discretion—and thus not reviewable by courts. And second, courts have resisted deferring to executive branch policies on the merits.
There is a long tradition that certain decisions are committed to the executive branch and thus beyond review by courts. This tradition is reflected in the Administrative Procedure Act, which says that matters "committed to agency discretion by law" are not reviewable. The Supreme Court has held that certain types of decisions—like the exercise of enforcement discretion—cannot be reviewed.
Yet courts have been more likely to apply a presumption in favor of judicial review in challenges to Trump Administration policies. In Trump v. Hawaii, for example, the Supreme Court refused to accept the government's argument that the Court had no role to play in reviewing the president's proclamation. And in the census case, the Supreme Court rejected the government's argument that it could not review the decision to add a citizenship question. The DACA cases, which the Court agreed to hear this term, will again test the government's argument that matters of enforcement discretion are committed to the executive branch.
Just as courts are resisting nonreviewability arguments, courts are also resisting requests to defer to the executive branch on the merits. Doctrines of judicial deference to the merits of executive branch policymaking—Chevron deference to interpretations of statutory ambiguities and Auer deference to interpretations of regulatory ambiguities—have long been debated and now seem to rest on shaky legal footing.
The Supreme Court entered this debate in Kisor v. Wilke. Although a divided court declined to overrule Auer deference, four justices would have done so. For his part, the Chief Justice wrote separately to emphasize Auer's limitations, and he signaled that the court's decision in Kisor had no bearing on issues surrounding Chevron deference.
Although the court has not considered the validity of that doctrine since City of Arlington v. FCC, the court has considered Chevron's underpinnings: Congress's delegation of lawmaking power to the executive branch through statutory silence and ambiguity.
Gundy v. United States was the Supreme Court's latest attempt to grapple with a broad delegation of lawmaking power to the executive branch. Although a plurality upheld the statute at issue, four justices (excluding Justice Kavanaugh, who did not participate) were willing to reconsider the nondelegation doctrine. Look for the Supreme Court to be called upon again soon to decide whether other laws are impermissible delegations of lawmaking power to the executive branch.
These recent trends have altered the course of regulatory litigation. Federal district courts are now exercising their power of judicial review by considering multiple challenges to executive branch policies, ordering discovery and avoiding deference. Each of these trends should be taken into account before engaging in regulatory litigation.
Donald F. McGahn II leads the government regulation practice at Jones Day. Before rejoining Jones Day in 2019, he served as counsel to the president of the United States. Brett A. Shumate is also a partner in the government regulation practice. Before joining Jones Day, he served in the U.S. Department of Justice as deputy assistant attorney general for the civil division's federal programs branch. This article represents the personal views and opinions of the authors and not necessarily those of the law firm with which they are associated.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllShould It Be Left to the Plaintiffs Bar to Enforce Judicial Privacy Laws?
7 minute readA Reporter and a Mayor: Behind the Scenes During the Eric Adams Indictment News Cycle
Of Predictive Analytics and Robots: A First-Year Federal Judge's Thoughts on AI
Trending Stories
- 1Judicial Ethics Opinion 24-68
- 2Friday Newspaper
- 3Judge Denies Sean Combs Third Bail Bid, Citing Community Safety
- 4Republican FTC Commissioner: 'The Time for Rulemaking by the Biden-Harris FTC Is Over'
- 5NY Appellate Panel Cites Student's Disciplinary History While Sending Negligence Claim Against School District to Trial
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250