Wrenn v. District of Columbia, 420 U.S. App. D.C. 309

Appellants (District of Columbia and its Police Chief) appealed a preliminary injunction that barred enforcement of D.C.’s "good reason" requirement for concealed-carry licenses.
The district court judge who issued the injunction was Senior Judge Frederick J. Scullin, Jr., a judge of the Northern District of New York sitting as a visiting judge in D.C.
Judge Scullin had been designated to hear certain specified related matters, but his designation did not include the present case.
The D.C. court’s calendar committee assigned the matter to Judge Scullin on the ground it was related to a case he was handling, but the Chief Justice’s designation did not encompass this particular litigation.
The D.C. Circuit resolved the appeal on jurisdictional grounds, concluding Judge Scullin lacked authority to enter the injunction because his limited designation did not cover this case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a visiting senior judge had authority to decide this D.C. case	Appellees (Renn) implicitly relied on the court’s assignment and de facto validity of acts	Appellants (D.C.) argued the judge lacked designation authority for this case	Judge lacked jurisdiction; decision vacated
Whether the de facto officer doctrine validates acts by a judge acting beyond designation	Appellees argued de facto officer doctrine should validate the injunction	Appellants contended designation limits are jurisdictional and not technical defects	De facto officer doctrine inapplicable; designation limits are jurisdictional
Whether a limited designation that covered related cases extends to subsequently assigned related matters	Appellees relied on related-case assignment to justify jurisdiction	Appellants said statutory designation controls, not local assignment practices	Local calendar assignment cannot cure absence of Chief Justice designation
Remedy for action taken without proper judicial designation	Appellees sought to uphold the injunction despite defect	Appellants sought vacatur of the injunction	Court vacated the injunction as entered by a judge acting without jurisdiction

Frad v. Kelly, 302 U.S. 312 (1937) (orders issued by a visiting judge after expiration or beyond scope of designation are null)
United States v. American-Foreign Steamship, 363 U.S. 685 (1960) (judgments must be vacated when a judge sat in violation of statutory limits)
Nguyen v. United States, 539 U.S. 69 (2003) (discusses the de facto officer doctrine and its limits)