Overview

• A divided three-judge panel ruled 2-1 that the district court lacked jurisdiction under the Administrative Procedure Act to block mass firings at the Consumer Financial Protection Bureau.
• The majority held that employment-loss claims must be brought through the Civil Service Reform Act’s specialized review process rather than in federal district court.
• Judge Cornelia Pillard dissented, warning that the decision could allow the executive branch to neutralize or effectively dismantle a congressionally created agency.
• If plaintiffs secure an en banc rehearing, any implementation of layoffs and contract terminations could be stayed pending a full-court review.
• The ruling clears the way for acting CFPB director Russell Vought to resume plans to cut roughly 1,500 of the bureau’s 1,700 employees and cancel contracts, raising questions about the agency’s enforcement capacity.