In an oral argument that lasted nearly 90 minutes, the panel of 10 judges of the U.S. Court of Appeals for the District of Columbia Circuit repeatedly asked Gibson Dunn & Crutcher LLP’s Mark A. Perry how other federal ALJs would be affected by a ruling SEC judges were constitutionally infirm.
The only question in this case concerns the SEC’s administrative law judges, Perry responded, saying the impact on ALJs in other agencies is a question for another day.
‘Enforcement 40’ for 2020
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