Boyle v. Trump
8:25-cv-01628
| D. Maryland | Jun 13, 2025Background
- Plaintiffs (Boyle, Hoehn-Saric, Trumka Jr.) were duly appointed CPSC Commissioners, serving fixed terms with removal only allowed for neglect of duty or malfeasance per 15 U.S.C. § 2053(a).
- In May 2025, President Trump (via his agents) summarily terminated all three plaintiffs without cause, barring their access to CPSC facilities and resources.
- Plaintiffs filed suit seeking declaratory and injunctive relief, arguing their removal was unlawful and requesting reinstatement.
- Defendants (Trump et al.) argued that the for-cause removal restriction violated the President’s Article II constitutional removal power.
- Both sides moved for summary judgment; the court found facts undisputed and proceeded to rule on the legal question.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of for-cause removal restriction | For-cause restriction valid under Humphrey's Executor and precedent for multimember regulatory commissions | Restriction infringes Article II presidential removal power | For-cause removal restriction is constitutional; statute upheld |
| Lawfulness of the removals | Removal without cause violates statute and is ultra vires | President has inherent constitutional power to remove | Removals were unlawful under 15 U.S.C. § 2053(a) |
| Availability of injunctive/declaratory relief | Both forms of relief appropriate to remedy wrongful removal | Court lacks authority to reinstate agency officials | Declaratory and injunctive relief appropriate; reinstatement ordered |
| Nature of CPSC as qualifying under Humphrey’s Executor | CPSC is like the FTC: a multimember, bipartisan commission with quasi-judicial/legislative functions | CPSC wields more executive power than FTC; should be treated differently | Court finds CPSC’s structure/function matches Humphrey’s; protection applies |
Key Cases Cited
- Humphrey's Executor v. United States, 295 U.S. 602 (1935) (upheld for-cause removal protection for FTC commissioners and established framework for independent agencies)
- Wiener v. United States, 357 U.S. 349 (1958) (affirmed application of Humphrey’s Executor to other independent commissions with quasi-judicial functions)
- Morrison v. Olson, 487 U.S. 654 (1988) (declined rigid categorization; allowed for-cause restrictions for certain officials)
- Seila Law LLC v. Consumer Financial Protection Bureau, 591 U.S. 197 (2020) (invalidated for-cause restriction for single-director CFPB but reaffirmed Humphrey’s Executor for multimember boards)
- Myers v. United States, 272 U.S. 52 (1926) (established general presidential removal power, but recognized by later cases as not absolute)