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Lucia v. Securities and Exchange Commission
United States Supreme Court
138 S.Ct. 2044, 201 L.Ed.2d 464 (2018)
The Securities and Exchange Commission (SEC) (defendant) instituted an administrative proceeding against Raymond Lucia (plaintiff). An administrative-law judge for the SEC, who held a career appointment, found that Lucia had violated federal investment law. The administrative-law judge made factual findings and imposed significant sanctions on Lucia. Lucia appealed the decision, arguing that the administrative proceeding was invalid because the administrative-law judge had not been constitutionally appointed. According to Lucia, administrative-law judges were officers of the United States and thus were subject to the Constitution’s Appointments Clause. Under this clause, federal employees deemed officers of the United States could be appointed only by the President or the head of a department. The SEC left the task of appointing administrative-law judges to SEC staff members. Thus, Lucia contended, the judge in his case lacked constitutional authority to do his job. The SEC rejected Lucia’s argument and held that administrative-law judges were mere employees, not officers. Thus, according to the SEC, administrative-law judges were not subject to the Appointments Clause. Lucia then brought his case to a federal appeals court, which also rejected his argument. The Supreme Court then granted cert.
Rule of Law
Holding and Reasoning (Kagan, J.)
Concurrence (Thomas, J.)
Concurrence/Dissent (Breyer, J.)
Dissent (Sotomayor, J.)
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