Skyworks, Ltd. v. Centers for Disease Control and Prevention, 542 F.Supp.3d 719

Background

Plaintiffs (landlords, property managers, and a trade association) previously prevailed on the merits: the court held the CDC’s nationwide eviction moratorium exceeded the agency’s authority under 42 U.S.C. § 264(a) and entered judgment invalidating the orders.
Plaintiffs moved under Rule 59(e) to amend/clarify the prior judgment to state whether the court’s remedy (invalidating CDC action) applies nationwide or only to the parties and their associational members.
Defendants argued plaintiffs lacked standing to seek relief for non‑parties and that the court should not extend vacatur beyond the parties; they also urged denial under Rule 59(e).
The court concluded the Rule 59(e) motion presented an exceptional case warranting clarification, reaffirmed plaintiffs’ standing to seek clarification, and analyzed (1) the scope of declaratory judgments and (2) the scope of vacatur under the Administrative Procedure Act (APA).
The court held that the declaratory judgment binds only the parties and their members (wherever located) and declined to order or declare nationwide vacatur under the APA, leaving broader questions about nationwide relief to higher courts or Congress.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to seek broader remedy	Plaintiffs may seek clarification of the prior judgment; they already had standing on the merits	Plaintiffs lack standing to expand relief to non‑parties	Court: plaintiffs have standing to seek clarification of the remedy tied to litigation they won
Rule 59(e) relief to clarify scope	Motion appropriately seeks to amend judgment to clarify remedial scope	Motion is an improper re‑argument or new claim	Court: rare/exceptional circumstances here justify Rule 59(e) consideration
Scope of declaratory judgment	Declaratory relief should invalidate CDC action broadly	Declaratory judgment should bind only parties	Court: declaratory judgment binds only the parties and their members, wherever they may be
Scope of APA vacatur (nationwide relief)	APA permits (or requires) vacatur of unlawful agency action beyond parties when the rule is of broad applicability	APA does not authorize nationwide relief here; prudential and Article III limits counsel restrict remedy	Court: declines to extend vacatur nationwide; the scope of broad vacatur is unsettled and better addressed by appellate courts or Congress

Key Cases Cited

Ex parte Young, 209 U.S. 123 (1908) (authorizes suits to enjoin state officials for federal‑law violations)
Aetna Life Ins. Co. v. Haworth, 300 U.S. 227 (1937) (upheld constitutionality of Federal Declaratory Judgment Act)
Zwickler v. Koota, 389 U.S. 241 (1967) (declaratory and injunctive relief are distinct remedies requiring separate analysis)
Younger v. Harris, 401 U.S. 37 (1971) (principles of comity/federalism limit federal injunctive relief against state prosecutions)
Samuels v. Mackell, 401 U.S. 66 (1971) (declaratory relief can have practical effects similar to injunctions)
Perez v. Ledesma, 401 U.S. 82 (1971) (discusses differences in relief and effects of declaratory judgments)
Lujan v. National Wildlife Federation, 497 U.S. 871 (1990) (discussion of scope of APA review and the limits of challenges to broadly applicable agency action)
Trump v. Hawaii, 138 S. Ct. 2392 (2018) (Justice Thomas concurrence criticizing nationwide injunctions; debate among Justices over scope of equitable relief)
Department of Homeland Sec. v. New York, 140 S. Ct. 599 (2020) (stay pending appeal; concurring views questioning nationwide injunctions)
National Mining Ass’n v. United States Army Corps of Eng’rs, 145 F.3d 1399 (D.C. Cir. 1998) (when agency regulation is unlawful, ordinary result is vacatur of the rule)
Gun Owners of Am., Inc. v. Garland, 992 F.3d 446 (6th Cir. 2021) (guidance limiting injunction scope to circuit boundaries and parties; illustrates circuit reluctance to issue nationwide injunctions)
Columbia Broad. Sys. v. United States, 316 U.S. 407 (1942) (discusses challenges to agency regulations of broad applicability)