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Polyweave Packaging, Inc. v. Peter ButtigiegPolyweave Packaging, Inc. v. Peter Buttigieg

Court of Appeals for the Sixth Circuit
Oct 20, 2022
21-5929
Versions:51 F.4th 675

RECOMMENDED FOR PUBLICATION

Pursuant to Sixth Circuit I.O.P. 32.1(b)

File Name: 22a0230p.06

UNITED STATES COURT OF APPEALS

FOR THE SIXTH CIRCUIT

POLYWEAVE PACKAGING, INC., a Delaware

corporation,

Plaintiff-Appellant,

v.

PETER PAUL MONTGOMERY BUTTIGIEG, Secretary,

United States Department of Transportation, in his

official capacity,

Defendant-Appellee.

No. 21-5929

Appeal from the United States District Court for the Western District of Kentucky at Owensboro.

No. 4:21-cv-00054—Joseph H. McKinley, Jr., District Judge.

Argued: May 5, 2022

Decided and Filed: October 20, 2022

Before: ROGERS, KETHLEDGE, and MURPHY, Circuit Judges.


COUNSEL

ARGUED: Sheng Li, NEW CIVIL LIBERTIES ALLIANCE, Washington, D.C., for Appellant.

Edward Himmelfarb, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for

Appellee. ON BRIEF: Sheng Li, NEW CIVIL LIBERTIES ALLIANCE, Washington, D.C.,

Christopher Wiest, CHRIS WIEST, ATTORNEY AT LAW, PLLC, Crestview Hills, Kentucky,

for Appellant. Edward Himmelfarb, UNITED STATES DEPARTMENT OF JUSTICE,

Washington, D.C., for Appellee.

ROGERS, J., delivered the opinion of the court in which KETHLEDGE, J., joined.

MURPHY, J. (pp. 16–25), delivered a separate opinion concurring in the judgment.

_________________

OPINION

_________________

ROGERS, Circuit Judge. When Congress places judicial review of certain types of

agency action in the court of appeals rather than the district court, this jurisdictional allocation

cannot be circumvented by suing in the district court to challenge agency procedures used (or

omitted) in the proceedings leading to such actions, at least where court-of-appeals jurisdiction

provides a fully effective forum to address such arguments. This venerable principle without

more supports the district court’s dismissal of plaintiff’s claims in this case.

Plaintiff Polyweave Packaging, Inc. makes packaging for the safe transportation of

hazardous materials. Following an investigation of Polyweave, the Pipeline and Hazardous

Materials Safety Administration—an operating administration within the Department of

Transportation—issued an order finding that Polyweave had violated federal regulations and

assessed a civil penalty of $14,460. In addition to seeking judicial review of that civil-penalty

order in the court of appeals, Polyweave brought this action in district court seeking injunctive

and declaratory relief to prevent the Department of Transportation from rescinding a regulation

known as Subpart D. Subpart D sets forth several requirements for enforcement actions taken by

DOT operating administrations, such as the enforcement proceeding against Polyweave.

Polyweave argues that the DOT improperly rescinded Subpart D and alleges that Polyweave has

incurred procedural injury in the underlying enforcement proceeding as a result. The district

court however lacked jurisdiction over Polyweave’s claims because the court of appeals’

exclusive jurisdiction over judicial review of the underlying agency order bars Polyweave from

attempting to litigate the rescission of Subpart D in the district court.

I.

As alleged in the complaint, the Pipeline and Hazardous Materials Safety Administration

(PHMSA) began investigating Polyweave in March 2015 after one of the PHMSA’s inspectors

paid an unannounced visit to Polyweave’s Madisonville, Kentucky facility. On December 30,

2016, PHMSA attorneys signed a Notice of Probable Violation, alleging that Polyweave had

committed four violations of federal regulations prior to November 2015. Polyweave learned

about that notice in February 2017, and Polyweave’s president asked the PHMSA’s Office of

Chief Counsel to adjudicate the matter. The PHMSA’s Chief Counsel issued an order on July

20, 2020, finding that Polyweave had committed the violations and assessing a fine of $14,460.

Polyweave was served with this order on March 8, 2021,1 and Polyweave timely filed an

administrative appeal. After Polyweave filed the separate lawsuit in district court, the PHMSA

issued a final order denying Polyweave’s administrative appeal, and Polyweave timely filed an

appeal of that order to the Sixth Circuit pursuant to 49 U.S.C. § 5127.

The crux of the separate litigation in the district court below involves a set of regulations

known as Subpart D, which was originally promulgated by the Secretary of Transportation to

establish certain requirements to be followed in enforcement proceedings. Subpart D was

promulgated on December 27, 2019, following a memorandum by the DOT’s general counsel,

titled, “Procedural Requirements for DOT Enforcement Actions” and Executive Order 13982,

titled, “Promoting the Rule of Law Through Transparency and Fairness in Civil Administrative

Enforcement and Adjudication.” Administrative Rulemaking, Guidance, and Enforcement

Procedures, 84 Fed. Reg. 71714, 71715–16, 71718 (Dec. 27, 2019) (to be codified at 49 C.F.R.

§§ 5.53–5.111); see also R. 1-2 (General Counsel Memo); Promoting the Rule of Law Through

Transparency and Fairness in Civil Administrative Enforcement and Adjudication, 84 Fed. Reg.

55239 (2019) (Executive Order 13982). The then-Secretary, Elaine Chao, promulgated Subpart

D pursuant to her general rulemaking authority under 49 U.S.C. § 322(a). Administrative

Rulemaking, Guidance, and Enforcement Procedures, 84 Fed. Reg. at 71718. The DOT did not

engage in notice and comment rulemaking when adopting Subpart D because the final rule

“merely incorporate[d] existing internal procedures applicable to the Department’s

administrative procedures into the Code of Federal Regulations.” Id. at 71716.

Subpart D set out several requirements that “appl[ied] to all enforcement actions taken by

each DOT operating administration (OA) and each component of the Office of the Secretary of

Transportation (OST) with enforcement authority.” 49 C.F.R. § 5.53 (2020); Administrative

Rulemaking, Guidance, and Enforcement Procedures, 84 Fed. Reg. at 71729. Polyweave

Notes

1
The delay in Polyweave’s learning of the Notice of Probable Violation and the order was due to service at

the wrong address by the PHMSA.

acknowledges that some of these requirements are “procedural rules of agency organization,

procedure, or practice.” Polyweave also contends that some of the requirements in Subpart D are

“substantive rules affecting Polyweave’s due-process rights and protections.” These

requirements include: 49 C.F.R. §§ 5.59 (Enforcement policy generally), 5.61 (Investigative

functions), 5.65 (Proper exercise of prosecutorial and enforcement discretion), 5.67 (Duty to

review for legal sufficiency), 5.69 (Fair notice), 5.83 (Duty to disclose exculpatory evidence),

5.97 (Basis for civil penalties and disclosures thereof). See 84 Fed. Reg. at 71729–32. For

example, Subpart D requires DOT operating administrations—such as the PHMSA—to follow

the principle articulated in Brady v. Maryland, 373 U.S. 83 (1963), and disclose any exculpatory

evidence in the agency’s possession to the subject of the enforcement action. 49 C.F.R. § 5.83

(2020); see Administrative Rulemaking, Guidance, and Enforcement Procedures, § 5.83, 84 Fed.

Reg. at 71731.

On April 2, 2021, following the change of presidential administrations, the current

Secretary, Pete Buttigieg, rescinded Subpart D.2 See 86 Fed. Reg. 17292, 17294 (2021). The

Secretary did not engage in notice and comment as part of the decision to rescind Subpart D

because, he said, the rescission “revises only internal processes applicable to the Department’s

administrative procedures,” and the rule is therefore “a rule of agency procedure for which notice

and comment are not required.” 86 Fed. Reg. at 17293; see 5 U.S.C. § 553(b)(A).

While Polyweave’s administrative appeal of the civil-penalty order was pending,

Polyweave brought this action in district court seeking injunctive and declaratory relief to

prevent the Secretary from rescinding Subpart D. Polyweave explains in its appellate briefing

that it filed suit “to restore Polyweave’s due-process rights in its ongoing administrative appeal.”

In its complaint, Polyweave contended that, if the Secretary had not improperly rescinded the

requirements outlined in Subpart D, the PHMSA would not have been able to assess the civil

penalty against Polyweave in the underlying enforcement proceeding.

2
The Secretary rescinded Subpart D (April 2, 2021) after Polyweave filed its administrative appeal of the

civil-penalty order (March 25, 2021) but before Polyweave requested exculpatory evidence in the underlying

enforcement proceeding (May 6, 2021).

At bottom, Polyweave contends that the rescission of Subpart D violated the

Administrative Procedure Act for two reasons: first, Polyweave argues that the Secretary’s

decision should be set aside because the Secretary’s reasons for rescinding Subpart D are

“arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law”; second,

Polyweave asserts that the Secretary failed to provide it with notice and an opportunity to

comment on the decision to rescind Subpart D.

The Secretary moved to dismiss Polyweave’s claims, arguing that the district court

lacked jurisdiction because Polyweave did not have standing to assert those claims and because

49 U.S.C. § 5127 placed exclusive jurisdiction over Polyweave’s claims in the court of appeals,

not the district court. The district court granted the motion to dismiss. The district court

evaluated each of Polyweave’s asserted injuries and concluded that none was sufficient to

establish standing to challenge the rescission of Subpart D.

The district court also considered in the alternative whether Polyweave’s claim was

barred by the exclusive-jurisdiction provision of PHMSA’s organic statute. The court

determined that the language of the exclusive-jurisdiction provision, 49 U.S.C. § 5127, did not

bar Polyweave’s APA claims because the language of the statute limits the scope of the

exclusive jurisdiction to final action of the Secretary under Chapter 51 of Title 49 (enforcement

actions for transport of hazardous waste), not to “the Secretary’s rulemaking authority

generally.” Further, the court determined that Polyweave’s challenge was not inescapably

intertwined with the underlying enforcement action.

The court alternatively concluded that, even if it had jurisdiction, Polyweave was not

entitled to a preliminary injunction because Polyweave had not established a likelihood of

success on the merits of either of its claims or that Polyweave would suffer irreparable harm

without an injunction. With regard to Polyweave’s arbitrary-and-capricious claim, the court

determined that the Secretary’s decision to rescind Subpart D was judicially unreviewable

because the decision was committed to agency discretion by law. See 5 U.S.C. § 702(a)(2).

The court also concluded that Polyweave had not established a likelihood of success on

its notice-and-comment claim because the Secretary needed to use only the same procedures to

repeal Subpart D as were used to promulgate Subpart D. The court determined that since the

former Secretary did not engage in notice and comment to promulgate Subpart D, the Secretary

did not violate the APA’s notice-and-comment requirements when he rescinded Subpart D

without notice and comment. Relying on “the same reasons that doomed Polyweave’s standing

arguments,” the court also determined that Polyweave would not suffer irreparable harm without

a preliminary injunction. Polyweave appeals.

II.

We need not address either the district court’s standing analysis or its preliminary rulings

on the merits of Polyweave’s claims. Affirmance is required because the district court lacked

jurisdiction to consider Polyweave’s APA claims. The only plausible bases for asserting Article

III injury in this case, which involves enforcement procedures, can be asserted in review of the

agency action in which those procedures were applied or withheld, review that lies exclusively in

the court of appeals.

Under 49 U.S.C. § 5127(c) of the Hazardous Materials Transportation Act, “a person

adversely affected or aggrieved by a final action of the Secretary under [] chapter [51] may

petition for review of the final action in the United States Court of Appeals for the District of

Columbia or in the court of appeals for the United States for the circuit in which the person

resides or has its principal place of business.” That “court has exclusive jurisdiction, as provided

in subchapter II of chapter 5 of title 5, to affirm or set aside any part of the Secretary’s final

action and may order the Secretary to conduct further proceedings.” Id. This exclusive

jurisdiction applies to Polyweave’s enforcement proceeding brought by the PHMSA, an

operating administration of the DOT. The exclusive-jurisdiction provision applies also to

Polyweave’s APA claims here because Polyweave’s claims effectively seek a determination of

what procedures apply in Polyweave’s underlying enforcement proceeding, and Polyweave’s

APA claims are therefore inescapably intertwined with the civil-penalty order. Exclusive

jurisdiction “necessarily preclude[s] de novo litigation between the parties of all issues inhering

in the controversy, and all other modes of judicial review.” City of Tacoma v. Taxpayers of

Tacoma, 357 U.S. 320, 337 (1958).

Because Polyweave’s alleged injuries in this case are incurred as part of the enforcement

proceeding and Polyweave could argue on court-of-appeals review of the civil-penalty order that

Subpart D was invalidly rescinded, Polyweave’s claims brought in the district-court suit are

inescapably intertwined with the civil-penalty order and therefore outside the jurisdiction of the

district court. As the basis for challenging the rescission of Subpart D, Polyweave alleges that it

was injured by the civil-penalty order from the underlying enforcement proceeding. Each of

Polyweave’s standing arguments asserted that Polyweave was injured because of the alleged

failure to comply with Subpart D in the underlying proceeding. Moreover, the court of appeals

would have authority on direct review of the final PHSMA order to provide meaningful review

of Polyweave’s claim that Subpart D was improperly rescinded. To the extent that Polyweave

has standing at all to challenge the rescission of Subpart D, Polyweave’s claim that the Secretary

did not adhere to the APA when he rescinded Subpart D could be litigated as part of

Polyweave’s challenge to the civil-penalty order. For example, if the PHMSA argued on direct

review of its civil-penalty order that Polyweave is not entitled to the requirements in Subpart D

because that regulation was properly rescinded, Polyweave can argue that the PHMSA is still

required to follow Subpart D because the Secretary did not validly rescind Subpart D. As a

general matter, a party seeking appellate review of an agency order may raise procedural

challenges to the applicable agency regulations as a basis for reversing the order. See Oakbrook

Land Holdings, LLC v. Comm’r of Internal Revenue, 28 F.4th 700, 710 (6th Cir. 2022).

Both Supreme Court precedent and persuasive circuit cases illustrate that exclusive-

jurisdiction provisions apply to non-collateral issues such as Polyweave’s APA claims.

The Supreme Court’s opinion in City of Tacoma supports a broad interpretation of

exclusive statutory assignments to courts of appeals of the jurisdiction to review final agency

actions. In that case, the Federal Power Commission issued a license to construct a power plant

to the city of Tacoma. 357 U.S. at 326. The State of Washington appealed the issuance of that

license to the Ninth Circuit, which the Ninth Circuit eventually affirmed. Id. at 327–28. In a

separate state-court proceeding, however, Washington asserted a cross-claim that raised the same

objections Washington had made before the Ninth Circuit. Id. at 329. The Washington Supreme

Court affirmed a state-court order that enjoined the City from proceeding on the project. Id. at

332. The United States Supreme Court concluded that an exclusive-jurisdiction provision

required Washington to raise its objections to the license only in the relevant federal court of

appeals. Id. at 335–36. The Supreme Court explained:

It can hardly be doubted that Congress, acting within its constitutional powers,

may prescribe the procedures and conditions under which, and the courts in

which, judicial review of administrative orders may be had. So acting, Congress

in § 313(b) prescribed the specific, complete and exclusive mode for judicial

review of the Commission’s orders. It there provided that any party aggrieved by

the Commission’s order may have judicial review, upon all issues raised before

the Commission in the motion for rehearing, by the Court of Appeals which “shall

have exclusive jurisdiction to affirm, modify or set aside such order in whole or in

part,” and that “[t]he judgment and decree of the court, affirming, modifying , or

setting aside, in whole or in part, any such order of the Commission, shall be

final, subject to review by the Supreme Court of the United States upon certiorari

or certification.” It thereby necessarily precluded de novo litigation between the

parties of all issues inhering in the controversy, and all other modes of judicial

review. Hence, upon judicial review of the Commission’s order, all objections to

the order, to the license it directs to be issued, and to the legal competence of the

licensee to execute its terms, must be made in the Court of Appeals or not at all.

For Congress, acting within its powers, has declared that the Court of Appeals

shall have “exclusive jurisdiction” to review such orders, and that its judgment

“shall be final,” subject to review by this Court upon certiorari or certification.

Id. at 335–36 (internal citations omitted) (alteration in original, emphasis added). The Court

explained further that the scope of the exclusive-jurisdiction provision was not limited to the

objections actually raised in the Court of Appeals; the exclusive-jurisdiction provision barred all

claims that “could and should have been raised” in the Court of Appeals review of the

Commission’s order. Id. at 339.

Our sister circuits have consistently applied the principles in City of Tacoma to dismiss

district-court actions where the plaintiffs’ claims are inescapably intertwined with an

administrative order that is subject to an exclusive-jurisdiction provision. In Tur v. FAA, 104

F.3d 290 (9th Cir. 1997), for example, Tur brought suit against Federal Aviation Administration

(FAA) attorneys in district court after the FAA issued an order revoking Tur’s helicopter pilot’s

license. Id. at 291. Tur alleged that the FAA attorneys deprived him of a property interest (his

airman’s certificate) without due process by knowingly using false testimony against him in the

administrative proceeding. Id. The Ninth Circuit reasoned that Tur’s separate lawsuit was

inescapably intertwined with the FAA’s revocation order because “Tur’s suit, if allowed to

proceed, would result in a new adjudication over the evidence and testimony adduced in the

October 1991 hearing, the credibility determinations made by the ALJ, and, ultimately, the

findings made by the ALJ.” Id. at 292. The applicable exclusive-jurisdiction provision therefore

barred Tur from bringing a Bivens action to vindicate his constitutional rights in a separate suit.

Id. Polyweave’s APA claims suffer from the same flaw. If Polyweave were allowed to maintain

its APA claims against the Secretary in a separate suit, the district court would be required to

determine whether the PHMSA had complied with Subpart D—an issue that would be decided

on direct review—in the analysis of whether Polyweave had standing to bring the APA

challenge.

The Fifth Circuit reasoned similarly in another case involving an FAA order. Ligon v.

LaHood, 614 F.3d 150 (5th Cir. 2010). In that case the Fifth Circuit concluded that a district

court lacked jurisdiction to consider Ligon’s Age Discrimination in Employment Act (ADEA)

challenge to an FAA order. There the FAA issued an order declining to renew some of Ligon’s

delegated authority to inspect and issue certificates that identified aircraft as compliant with FAA

regulations. Id. at 152–53. Ligon filed suit in district court, seeking damages and injunctive

relief pursuant to the ADEA. Id. at 153. The Fifth Circuit noted that “district courts lack

jurisdiction not only over direct challenges to FAA orders, but also over damages claims that are

‘inescapably intertwined with a review of the procedures and merits surrounding an FAA

order,’” and “parties may not avoid administrative review simply by fashioning their attack on an

FAA decision as a constitutional tort claim against individual FAA officers.” Id. at 155 (citation

omitted). After surveying other circuits’ application of the same inescapable-intertwinement

test, the Fifth Circuit concluded that Ligon’s ADEA claims were inescapably intertwined with

the underlying administrative order for two reasons. First, “Ligon’s challenge requires a review

and balancing of the same evidence used by the FAA in deciding not to renew his areas of

authority, and is essentially a challenge to the merits and procedure of a particular order that is

currently pending against Ligon.” Id. at 157. Second, Ligon could have sought his requested

relief—reinstatement—in a direct review of the underlying proceeding. Id. Further, the Fifth

Circuit rejected the contention that the inescapable-intertwinement test could be limited to Bivens

claims; “[i]nstead, what matters is whether the challenge is inescapably intertwined with a

challenge to the order, and would therefore undermine Congress’s intention that FAA orders be

reviewed in a certain way.” Id. at 157 n.4. See also Merritt v. Shuttle, Inc., 187 F.3d 263, 265

(2d Cir. 1999).

To be sure, there are two cases in which our court has indicated that a district court could

properly exercise jurisdiction over a claim even though the claim was arguably inescapably

intertwined with an order reviewable exclusively in the court of appeals. But these cases are

categorically different. In Burdue v. FAA, 774 F.3d 1076 (6th Cir. 2014), we concluded that

Burdue’s Fifth Amendment due-process challenge to his termination was not inescapably

intertwined with the FAA’s order revoking his certificate to inspect aircraft. Although we

acknowledged our sister circuits’ cases that prohibited separate Bivens actions that required “a

review of the procedures and merits surrounding the FAA’s order,” we distinguished Burdue’s

claims because “Burdue’s constitutional claims are broad challenges to FAA procedures and are

not contingent on the merits of a particular FAA order.” Id. at 1083–84 (citations omitted). In

reaching this conclusion, we relied on McNary v. Haitian Refugee Ctr., Inc., 498 U.S. 479, 492

(1991) for the proposition that “a district court may review ‘general collateral challenges to

unconstitutional practices,’” at least where precluding review in the district court “would prevent

meaningful review of Burdue’s constitutional claims.” Id. at 1083–84. But Polyweave’s case

does not involve general collateral challenges to unconstitutional practices, and all of

Polyweave’s statutory and constitutional claims in this case can be meaningfully reviewed in

court of appeals review of the enforcement order. Polyweave’s claims are challenges under the

APA that Polyweave simply cannot bring independently of the enforcement proceeding that is

exclusively reviewable in the court of appeals.

In the second case, Mokdad v. Lynch, 804 F.3d 807 (6th Cir. 2015), we concluded that the

relevant exclusive-jurisdiction provision did not prohibit the district court from addressing the

separate suit. Id. at 815. There, the Government argued in effect that “a direct challenge to one

agency’s order is inescapably intertwined with another agency’s order.” Id. at 814. Mokdad’s

separate lawsuit was challenging the Terrorist Screening Center’s (TSC) decision to place him

on the No Fly List. Id. at 809. The administrative order subject to an exclusive-jurisdiction

provision, however, was the Transportation Security Administration’s (TSA) order that denied

Mokdad’s relief under the Traveler Redress Inquiry Program. Id. The TSC is an interagency

center administered by the FBI while the TSA is located within the Department of Homeland

Security. Id. at 809, 812. Congress separated the responsibility for placing individuals on the

No Fly List (TSC) from the responsibility to establish redress procedures for travelers who think

they were incorrectly included on the No Fly List (TSA). Id. at 812. As a result, “we decline[d]

to accept the government’s invitation to expand the inescapable-intertwinement doctrine so as to

find that Mokdad’s claim against the TSC is pulled within the ambit of the exclusive-review

statute that applies to TSA.” Id. at 815. Polyweave’s claim here clearly differs from the claims

in Mokdad because Polyweave is not challenging the action of a separate agency. Instead,

Polyweave is challenging the rules—set by the DOT—that apply in an administrative proceeding

run by the PHMSA, a part of the DOT. Our decision in Mokdad therefore does not require, or

even support, allowing Polyweave to maintain its APA claims in a separate action.

The conclusion that the exclusive-jurisdiction provision prohibits Polyweave from

litigating its APA claims in the district court is also consistent with the Supreme Court’s holding

in Free Enterprise Fund v. Public Company Accounting Oversight Board, 561 U.S. 477 (2010),

declining to interpret a statutory judicial review provision as exclusive, and distinguishing for

that purpose the reasoning of the Supreme Court in Thunder Basin Coal Co. v. Reich, 510 U.S.

200, 212–13 (1994). Though the Supreme Court generally assumes that procedures “are to be

exclusive” when Congress “creates procedures ‘designed to permit agency expertise to be

brought to bear on particular problems,’” that presumption does not apply to limit jurisdiction “if

‘a finding of preclusion could foreclose all meaningful judicial review’; if the suit is ‘wholly

collateral to a statute’s review provisions’; and if the claims are ‘outside the agency’s

expertise.’” Free Enter. Fund, 561 U.S. at 489 (quoting Thunder Basin Coal Co., 510 U.S. at

212–13). None of these characteristics supports allowing Polyweave to bring its APA claims in

a separate action before the district court.

First, barring Polyweave’s separate lawsuit would not deprive Polyweave of all

meaningful review of its claims. As discussed above, Polyweave could unquestionably have

obtained meaningful judicial review of its APA claims on direct review of the civil-penalty

order. Moreover, this is not a case where Polyweave is being forced to “‘bet the farm . . . by

taking violative action’ before ‘testing the validity of the law,’” such that Polyweave is therefore

unable to access a meaningful avenue of relief. See Free Enter. Fund, 561 U.S. at 490 (citations

omitted). Here, Polyweave does not challenge the PHMSA’s authority to conduct enforcement

proceedings; Polyweave takes issue only with the rules that apply once the PHMSA initiates

proceedings. The applicable rules only matter to Polyweave once it is the subject of an

enforcement proceeding. Thus, Polyweave can be injured from the rescission of Part D only in

the course of being the subject of an enforcement proceeding, and that enforcement proceeding

provides Polyweave a meaningful avenue of relief through direct review of the civil-penalty

order. As a result, Polyweave does not need to intentionally violate federal regulations to test the

validity of Subpart D; instead Polyweave must simply wait until it has suffered an alleged Article

III injury by being denied the requirements in Subpart D, and then Polyweave can litigate

Subpart D’s validity on direct review of any adverse order. Accordingly, requiring Polyweave to

litigate its APA claims on direct review of the civil-penalty order does not deprive Polyweave of

all meaningful review of those claims.

Second, Polyweave’s APA challenge to the rescission of Subpart D is not wholly

collateral to the civil-penalty order; indeed, it is not collateral at all. Polyweave’s objection to

the rescission of Subpart D requires that Polyweave be subject to Subpart D in the enforcement

process in order for Polyweave have standing at all to challenge the rescission. Polyweave

argues that its challenge to the rescission of Subpart D is entirely different from challenges to the

Secretary’s final action under Chapter 51, which are within the exclusive-jurisdiction provision

of 49 U.S.C. § 5127, because the DOT’s authority to issue and amend Subpart D comes from 49

U.S.C § 322. The Supreme Court considered and rejected a similar argument in Elgin v. Dep’t of

Treasury, 567 U.S. 1, 21 (2012). There, the petitioners contended that their bill-of-attainder and

sex-discrimination claims had “nothing to do with the types of day-to-day personnel actions

adjudicated by the MSPB.” Id. at 21–22. The Supreme Court rejected this contention because,

“[a]s evidenced by their district court complaint, petitioners’ constitutional claims are the vehicle

by which they seek to reverse the removal decisions, to return to federal employment, and to

receive the compensation they would have earned but for the adverse employment action.” Id. at

22. From the face of Polyweave’s complaint, Polyweave has brought its APA claims to the

recission of Subpart D in an effort to undo the underlying enforcement proceeding.

Polyweave’s complaint states, “Upon information and belief, but [for] its decision to imminently

rescind Subpart D, the Department would not, and indeed could not, have taken” enforcement

action against Polyweave for its alleged violation of federal regulations. Further, Polyweave’s

standing arguments each depend on Polyweave’s currently being subject to an enforcement

proceeding. Polyweave’s case also is not distinguishable on the ground that Polyweave has

drafted its lawsuit without seeking directly to enjoin the civil-penalty order. But by seeking a

ruling about what rules apply in the underlying enforcement proceeding, Polyweave is

effectively attacking the validity of the civil-penalty order. To conclude otherwise would prove

too much. A party could always circumvent an exclusive-jurisdiction provision applicable to

agency action by challenging the promulgation/rescission of the rules used in an agency

proceeding rather than the order resulting from the proceeding. As a result, Polyweave’s APA

claims are not collateral, much less “wholly” collateral, to the civil-penalty order.

Third, Polyweave’s claims do not fall entirely outside the PHMSA’s expertise. True, the

PHMSA may not be able to adjudicate the specific claim that the Secretary violated the APA

when he rescinded Subpart D, but the PHMSA’s expertise could be brought to bear on other

issues that could resolve the enforcement proceeding in Polyweave’s favor. For example, the

PHMSA could have concluded that it did follow all of the procedures in Subpart D, regardless of

whether Subpart D was rescinded—as the PHMSA has in fact claimed—and if confirmed on

direct review, that would mean that Polyweave has suffered no harm that would give it standing

to challenge the rescission of Subpart D. Or, the PHMSA could simply conclude—as Polyweave

claims it should—that Polyweave did not violate any regulations, and that would resolve

Polyweave’s enforcement proceeding in its favor. As the Supreme Court has explained in

another context, where an agency’s “expertise can otherwise be ‘brought to bear’ on [] appeals

that challenge the constitutionality of a statute, we see no reason to conclude that Congress

intended to exempt such claims from exclusive review [before the agency and the court of

appeals].” Elgin, 567 U.S. at 23 (quoting Thunder Basin, 510 U.S. at 214–15). Because the

PHMSA’s expertise could be brought to bear on various issues that address Polyweave’s

enforcement proceeding, the possibility that the PHMSA might not be able to adjudicate

Polyweave’s APA claim does not support presuming that the claim falls outside the exclusive-

jurisdiction provision in 49 U.S.C. § 5127. Thus, none of the Thunder Basin factors supports

allowing Polyweave to bring its APA claims in a separate suit before the district court.

We recognize that the Supreme Court has granted certiorari in cases from two other

circuits involving whether district courts lack jurisdiction to review, in particular, Appointments

Clause challenges to the legitimacy of administrative law judges, because of organic act

provisions permitting federal court of appeals review of the agency’s final orders. See Cochran

v. SEC, 20 F.4th 194, 198 (5th Cir. 2021) (en banc); Axon Enter., Inc. v. FTC, 986 F.3d 1173,

1180 (9th Cir. 2021). Over a strong dissent, the en banc Fifth Circuit in Cochran held that

15 U.S.C. § 78y of the Securities Exchange Act did not preclude such an action in the district

court, while the Ninth Circuit held to the contrary under analogous provisions of the Federal

Trade Act, 986 F.3d at 1181-89, finding support in opinions of the D.C., Second, and Fourth

Circuits. Id. at 1188. The Fifth Circuit’s outlier decision in Cochran, however, is in any event

distinguishable from Polyweave’s case. The Fifth Circuit relied specifically not only on the

permissive nature of the grant of jurisdiction to the court of appeals in 5 U.S.C. § 78y of the

Securities Exchange Act, but also on a negative inference from explicit language in 15 U.S.C.

§ 78y(a)(3) providing that court of appeals jurisdiction “becomes exclusive” only on the filing of

the petition from the order and the SEC’s filing of its record. Cochran v. SEC, 20 F.4th at 207.

There is no such timing limitation in § 5127. The Fifth Circuit also relied strongly on the

structural nature of Cochran’s challenge:

The nature of [Cochran’s] challenge is structural—it does not depend on the

validity of any substantive aspect of the Exchange Act, nor of any SEC rule,

regulation, or order. Indeed, she is challenging the Exchange Act’s statutory-

review scheme itself. . . . Further, the outcome of her constitutional challenge to

the ALJs’ removal protection will have no bearing on her ultimate liability for

allegedly violating the securities laws.

Cochran v. SEC, 20 F.4th at 207. Polyweave’s challenges are plainly not “structural” in the

sense relied upon by the Fifth Circuit.

Finally, there is no merit to Polyweave’s contention at oral argument that requiring it to

bring its claims on direct appeal through 49 U.S.C. § 5127 would create a nonsensical

dichotomy. The asserted anomaly is that the exclusive-jurisdiction provision would apply to

Polyweave’s claims if Polyweave was subject to an enforcement proceeding, but the provision

would not apply if Polyweave—or some other party—filed the same challenge before it was

subject to an enforcement proceeding. Oral Argument at 5:54–6:15. That argument appears to

suggest that parties with generalized grievances might be able to challenge the rescission of

Subpart D, which itself is a dubious proposition. The argument fails to recognize that each of

Polyweave’s standing arguments depends on Polyweave’s currently being subject to an

enforcement proceeding. Polyweave does not explain how the existence—or absence—of

administrative proceedings would affect the court in which a party could challenge the rescission

of Subpart D. In other words, to the extent that Polyweave had standing at all to challenge the

recission of Subpart D, Polyweave can do so only on direct review of the civil-penalty order

pursuant to 49 U.S.C. § 5127.

III.

For the foregoing reasons, we affirm the district court’s dismissal of Polyweave’s APA

claims on the alternative ground that these claims are covered by the exclusive-jurisdiction

provision in 49 U.S.C. § 5127(c).

CONCURRING IN THE JUDGMENT

MURPHY, Circuit Judge, concurring in the judgment. In December 2019, the Secretary

of Transportation issued a final rule listing various procedures in the Code of Federal

Regulations that agency officers should follow in all enforcement proceedings. In April 2021,

after a change in administrations, the Secretary issued another final rule rescinding these

procedural regulations. Enmeshed in an enforcement proceeding throughout this time,

Polyweave Packaging sued the Secretary over the decision to rescind the regulations. I agree

with my colleagues that we should affirm the district court’s dismissal of Polyweave’s suit. But

I would take a different path to that result. I would not hold that the district court lacked

jurisdiction because of a statute that gives circuit courts the exclusive power to review the “final

action” in Polyweave’s specific enforcement proceeding. When Polyweave sued, the agency had

not even issued that action. My colleagues’ holding also implicates an issue pending at the

Supreme Court that has engendered a circuit split. I would instead follow the district court’s

reasoning: Polyweave failed to plead how the Secretary’s rescission harmed it. The company

thus lacks Article III standing to challenge the rescission.

*

The Secretary of Transportation enforces the laws (located in Chapter 51 of Title 49) that

regulate the transportation of hazardous materials. See 49 U.S.C. §§ 5101–5128. Congress has

delegated the Secretary’s power to a subagency in the Department of Transportation: the Pipeline

& Hazardous Materials Safety Administration (PHMSA). See id. § 108(f). PHMSA has read

this delegation as giving it the power to issue civil penalties for violations of the chapter. See id.

§ 5123(a)–(c). Regulations govern the process by which PHMSA imposes civil penalties.

49 C.F.R. §§ 107.307–.331. The agency first must issue a notice of probable violation, and the

alleged offender may request an informal or formal hearing. Id. §§ 107.311, -.317, -.319. If the

agency sticks with the finding of a violation after this hearing, the offender may appeal to the

PHMSA’s administrator. Id. § 107.325(a)–(b). The administrator then issues the final agency

decision. See id. § 107.325(d).

Congress has granted jurisdiction to the circuit courts to review a “final action” of

PHMSA that imposes a civil penalty for a violation of Chapter 51:

Except as provided in section 20114(c), a person adversely affected or aggrieved

by a final action of the Secretary under this chapter may petition for review of

the final action in the United States Court of Appeals for the District of Columbia or

in the court of appeals for the United States for the circuit in which the person

resides or has its principal place of business. The petition must be filed not more

than 60 days after the Secretary’s action becomes final.

49 U.S.C. § 5127(a). This section goes on to make clear that the aggrieved party must seek

review exclusively through its procedure: “The court has exclusive jurisdiction, as provided in

subchapter II of chapter 5 of title 5, to affirm or set aside any part of the Secretary’s final action

and may order the Secretary to conduct further proceedings.” Id. § 5127(c).

According to Polyweave’s complaint in this case, PHMSA issued a notice of probable

violation to the company. Compl., R.1, PageID 13. Polyweave requested an informal hearing.

Id. PHMSA’s chief counsel found a violation and issued a fine. Id. In March 2021, Polyweave

filed an appeal within the agency, as permitted by 49 C.F.R. § 107.325. Id., PageID 14.

In October, PHMSA’s Chief Safety Officer rejected Polyweave’s appeal and upheld the fine.

See Polyweave Packaging, Inc., Docket No. PHMSA-2020-0079 (Oct. 18, 2021). (It is unclear

whether the administrator has properly delegated the duty to resolve appeals to this officer.

Cf. 49 U.S.C. § 108(e); 49 C.F.R. § 107.301.) Polyweave filed a different petition for review in

our court to challenge this “final action” under 49 U.S.C. § 5127(a). See Pet., R.1, No. 21-4202

(6th Cir.).

This suit does not challenge that final action. It instead concerns the Department of

Transportation’s evolving rulemaking. In December 2019, the Department placed procedural

guidelines in the Code of Federal Regulations (at Part 5 of Title 49) to make transparent the rules

that officers should follow when engaging in rulemakings, issuing guidance, or prosecuting

enforcement actions. See 84 Fed. Reg. 71,714 (Dec. 27, 2019) (codifying 49 C.F.R. §§ 5.1–

5.111). In Subpart D, the agency listed procedural protections for enforcement actions, including

that officers should disclose exculpatory evidence under Brady v. Maryland, 373 U.S. 83 (1963).

See 49 C.F.R. § 5.83 (2020). But the regulations also made clear that they merely adopted rules

to “improve the internal management” of the Department and did not create rights “enforceable”

in court. Id. § 5.111. Following a change in administrations, the new Secretary removed these

“internal policies and procedures” from the Code of Federal Regulations in part on the ground

that the agency need not publish them there. 86 Fed. Reg. 17,292, 17,292–93 (Apr. 2, 2021).

In May 2021, while Polyweave’s internal agency appeal over the civil penalty remained

pending before PHMSA’s Chief Safety Officer, the company filed this separate action in district

court. The action challenged the Secretary’s decision to rescind the procedural guidance from

the Code of Federal Regulations. Polyweave sought injunctive and declaratory relief against the

rescission of Subpart D’s procedures, claiming that the Secretary’s recission had violated the

Administrative Procedure Act (APA) for various reasons. Compl., R.1, PageID 5, 10–19.

The district court dismissed Polyweave’s complaint. The court held that the complaint

failed to plausibly plead Polyweave’s Article III standing to challenge the removal of Subpart D.

Polyweave Packaging, Inc. v. Buttigieg, 2021 WL 4005616, at *3–10 (W.D. Ky. Sept. 2, 2021).

It did not, by contrast, view the judicial-review provision for challenging PHMSA’s “final

actions” (49 U.S.C. § 5127) as eliminating its subject-matter jurisdiction over this suit. Id. at

*10.

*

My colleagues hold that 49 U.S.C. § 5127 gives circuit courts exclusive jurisdiction not

just over a suit challenging PHMSA’s final action in an enforcement proceeding but also over a

suit that challenges other agency conduct that is “inescapably intertwined” with a PHMSA final

action. For two reasons, I would not take this route to the resolution of Polyweave’s suit.

First, this jurisdictional question implicates a circuit split that the Supreme Court will

soon resolve. The en banc Fifth Circuit recently addressed a similar issue involving a statute

(which mirrors § 5127) that grants circuit courts exclusive jurisdiction to review the SEC’s final

orders. See Cochran v. SEC, 20 F.4th 194, 198 (5th Cir. 2021) (en banc) (discussing 15 U.S.C.

§ 78y). The court held that this provision did not strip a district court of the jurisdiction to

entertain a constitutional challenge to the SEC’s structure brought by a private party subject to an

ongoing SEC proceeding. See id. at 199–212. The Ninth Circuit, by contrast, recently addressed

a similar issue involving a law granting circuit courts jurisdiction to review the FTC’s cease-and-

desist orders. See Axon Enter., Inc. v. FTC, 986 F.3d 1173, 1180 (9th Cir. 2021) (discussing 15

U.S.C. § 45(c)). The court held that this provision stripped a district court of the jurisdiction to

consider a constitutional challenge to the FTC’s structure and procedures brought by a private

party subject to an ongoing FTC proceeding. Id. at 1177–89. The Supreme Court granted

review in both cases. See SEC v. Cochran, 142 S. Ct. 2707 (2022); Axon Enter., Inc. v. FTC,

142 S. Ct. 895 (2022).

I do not see much daylight between these two cases and Polyweave’s case. Each one

involves a legal challenge to an agency’s general structure or procedures brought by a private

party who was then immersed in an agency proceeding. In none of the cases, however, had the

agency issued a final action in the party’s own proceeding. If the Supreme Court agrees with the

Ninth Circuit in Axon that the district court lacked subject-matter jurisdiction, it would go a long

way toward vindicating my colleagues’ reasoning here. If, by contrast, the Supreme Court

agrees with the Fifth Circuit in Cochran that the district court had subject-matter jurisdiction, it

would go a long way toward showing that they mistakenly find that the district court lacked

jurisdiction. Given the unsettled nature of the law on this significant legal question, I would opt

to avoid it.

Second, I tend to agree with the reasoning of the Fifth Circuit over the Ninth. If one

views this interpretive question through the Supreme Court’s modern textualist lens, the question

does not look particularly difficult. Cf. Nat’l Ass’n of Mfrs. v. Dep’t of Def., 138 S. Ct. 617,

631–34 (2018). Just as nothing in the text of 15 U.S.C. § 78y strips district courts of jurisdiction

over a constitutional challenge to the SEC’s structure, see Cochran, 20 F.4th at 199–201, so too

nothing in the text of 49 U.S.C. § 5127 strips district courts of jurisdiction over a challenge to the

Secretary of Transportation’s rule rescinding Subpart D. The text gives circuit courts exclusive

jurisdiction only over “a final action of the Secretary under this chapter[.]” 49 U.S.C. § 5127(a),

(c). Yet Polyweave did not seek review of PHMSA’s “final action” imposing a civil penalty

under Chapter 51. Indeed, PHMSA did not issue that final action until months after Polyweave

sued. The company instead sought review of the Secretary’s general rulemaking. And while the

Secretary’s rescission of Subpart D qualified as “final,” the Secretary did not issue that general

change (which covered all areas subject to the Department of Transportation’s authority) “under”

the specific hazardous-materials chapter. The Secretary instead issued the change under his

general rulemaking power. See 86 Fed. Reg. at 17,294 (citing 49 U.S.C. § 322(a)); see also Nat’l

Ass’n of Mfrs., 138 S. Ct. at 629–30. So I do not see how § 5127 could be read to cover a suit

like this one.

To be sure, my colleagues rightly recognize that the caselaw in this area has not

traditionally focused on the text alone. Courts have developed two different common-law tests

to determine the reach of exclusive-review provisions like § 5127. On the one hand, many

decisions rely on City of Tacoma v. Taxpayers of Tacoma, 357 U.S. 320 (1958), to suggest that

an exclusive-review provision restricts review of other agency conduct that is “inescapably

intertwined” with the final action covered by the provision. See Mokdad v. Lynch, 804 F.3d 807,

812–13 (6th Cir. 2015); Merritt v. Shuttle, Inc., 245 F.3d 182, 187 (2d Cir. 2001) (Sotomayor,

J.); see also Ligon v. LaHood, 614 F.3d 150, 154–57 (5th Cir. 2010); Tur v. FAA, 104 F.3d 290,

292 (9th Cir. 1997).

On the other hand, the Supreme Court has since developed a broader test. In Thunder

Basin Coal Co. v. Reich, 510 U.S. 200 (1994), it identified three questions to consider when

deciding whether an exclusive-review provision covers a suit: Would preclusion of the challenge

“foreclose all meaningful judicial review”? Is the challenge “wholly collateral” to the agency

adjudication subject to the review provision? And is the challenge “outside the agency’s

expertise”? Free Enter. Fund v. Pub. Co. Acct. Oversight Bd., 561 U.S. 477, 489 (2010)

(quoting Thunder Basin, 510 U.S. at 212–13); see Elgin v. Dep’t of Treas., 567 U.S. 1, 15

(2012). Why do courts continue to rely on City of Tacoma’s inescapably intertwined test after

Thunder Basin? The answer is not obvious to me. That test addresses only the second Thunder

Basin factor: whether a suit is wholly collateral. See Bebo v. SEC, 799 F.3d 765, 773 & n.2 (7th

Cir. 2015); cf. Miriyeva v. U.S. Citizenship & Immigr. Servs., 9 F.4th 935, 941–42 (D.C. Cir.

2021).

In all events, the Supreme Court in recent years has sometimes confronted older

precedent that seemed to adopt a “functional” approach that decided how litigation should

progress based on what would best promote judicial efficiency. See Nat’l Ass’n of Mfrs., 138

S. Ct. at 631–34. The Court has refused to extend the logic of this precedent when it was

“completely unmoored from the statutory text.” Id. at 632. Because the Thunder Basin factors

strike me as potentially “unmoored” from the text in the same way, the Court may well reach the

same result in this area.

Even still, it is not clear to me that these factors justify the conclusion that § 5127 strips

the district court of jurisdiction over Polyweave’s APA claims. Admittedly, Polyweave could

likely receive judicial review of the Secretary’s rescission of Subpart D through its petition for

review of PHMSA’s final action imposing a civil penalty. See Elgin, 567 U.S. at 17, 19. But

what would have happened if Polyweave had won that proceeding? How could it get review of

an agency’s general rule in that scenario? Cf. Free Enter. Fund, 561 U.S. at 490. In addition,

Polyweave’s suit is “collateral” to PHMSA’s final action in the sense that Polyweave seeks only

an injunction to reinstate Subpart D—not an injunction that would do anything to PHMSA’s civil

penalty. Cf. id. Unlike suits that seek to require an agency to arrive at a specific position in a

specific adjudication, cf. Elgin, 567 U.S. at 22, the company challenges the legality of the

Department of Transportation’s general procedures, cf. Bowen v. Mich. Acad. of Fam.

Physicians, 476 U.S. 667, 675–76 (1986). Lastly, PHMSA does not have any particular

“expertise” in handling such “standard questions of administrative law” as whether the Secretary

should have gone through notice-and-comment rulemaking when rescinding Subpart D. Free

Enter. Fund, 561 U.S. at 491.

*

I would instead affirm the district court’s holding that Polyweave lacks standing to

challenge the rescission of Subpart D. The Constitution gives us jurisdiction only over “Cases”

or “Controversies.” U.S. Const. art. III, § 2. To establish a case or controversy, Polyweave

needed to prove its standing. At the pleading stage, this element required the company to

plausibly allege that it has suffered (or would likely suffer) an injury, that this injury traces to the

elimination of Subpart D, and that its requested relief would redress (or prevent) the injury. See

Ass’n of Am. Physicians & Surgeons v. FDA, 13 F.4th 531, 536–37, 543–44 (6th Cir. 2021).

According to Polyweave, its complaint alleged that the Secretary’s rescission of

Subpart D caused four injuries. Polyweave argues that the rescission caused a constitutional

injury because (it says) parties have a due-process right to obtain exculpatory evidence in agency

proceedings under Brady. Appellant’s Br. 14–21. Even if Brady applies only in criminal

prosecutions, Polyweave next argues that the rescission took away its “substantive rights” that

Subpart D created. Id. at 21–26. Alternatively, Polyweave argues that it suffered an injury

because PHMSA denied it Brady materials in its own enforcement proceeding. Id. at 26–35.

Polyweave finally argues that it suffered a “pocketbook injury” because it had to pay its lawyers

to compel PHMSA to disclose those Brady materials. Id. at 35–37.

Each of these four standing theories falls short. The first two fail to allege a valid

Article III injury. The next two fail to satisfy Article III’s causation and redressability elements.

Theories One and Two. Polyweave’s first two standing theories flunk Article III’s injury

element. An Article III injury must be, among other things, particularized and concrete. See

Lujan v. Defs. of Wildlife, 504 U.S. 555, 560 (1992). The “particularized” element requires a

harm to affect a plaintiff in an individual way, not in the same way that it affects the public

generally. See Spokeo, Inc. v. Robins, 578 U.S. 330, 339 (2016) (quoting Lujan, 504 U.S. at 560

n.1). This element thus bars parties from litigating “generalized grievances.” See Carney v.

Adams, 141 S. Ct. 493, 498–99 (2020); Gill v. Whitford, 138 S. Ct. 1916, 1929–30 (2018); Lance

v. Coffman, 549 U.S. 437, 439 (2007) (per curiam); Ex parte Lévitt, 302 U.S. 633, 633–34 (1937)

(per curiam). As perhaps the most common “generalized grievance,” plaintiffs routinely

challenge government action as illegal on the ground that it injured their interest in “the rule of

law”—an interest that they share with everyone else. In re Cap. Contracting Co., 924 F.3d 890,

898 (6th Cir. 2019) (quoting Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83, 106 (1998)).

That type of injury does not suffice. See Lance, 549 U.S. at 441–42. Plaintiffs instead must

show that the action affected them specifically—because, for example, the government enforced

a challenged law against them. Cf. Trump v. Hawaii, 138 S. Ct. 2393, 2416 (2018); Davis v.

FEC, 554 U.S. 724, 733 (2008).

The “concrete” element, by comparison, requires that the plaintiff’s injury be “real”

rather than “abstract.” Spokeo, 578 U.S. at 340 (citation omitted). In recent years, the Supreme

Court has given this element new teeth. The Court has reaffirmed that Congress lacks unlimited

power to create a new “statutory right” and give the new right-holder a cause of action to sue

over the right’s violation. See TransUnion LLC v. Ramirez, 141 S. Ct. 2190, 2205–07 (2021);

Spokeo, 578 U.S. at 341. Rather, a violation of the new right will create a concrete injury only if

the violation resembles an injury that could create a “case” as a historical matter. See

TransUnion, 141 S. Ct at 2204. Traditional injuries include, for example, tangible harms to

persons or property. See id. They also include some intangible harms, such as constitutional

harms to free speech. See id.

Here, Polyweave’s first two theories do not allege an Article III injury for the same

reason: the company does not identify a particularized injury. According to the first theory,

Polyweave suffered a constitutional injury because the rescission of Subpart D violated due

process. According to the second theory, Subpart D at least created new regulatory rights and

the rescission of these rights (allegedly in violation of the APA) injured Polyweave. Yet

Polyweave makes both arguments in the “abstract”—as if the Secretary’s mere issuance of the

rule automatically injured the company. Carney, 141 S. Ct. at 499. Not so. These two theories

allege “nothing more than an abstract and generalized harm to a citizen’s interest in the proper

application of the law[.]” Id. at 498. That is, they allege a classic generalized grievance. See id.

at 498–99. Yet when an agency issues a regulation that violates, say, the Free Speech Clause,

the entire population does not immediately suffer a speech injury that allows everyone to

challenge the regulation’s validity. Instead, a plaintiff like Polyweave must show that the

challenged action (like the elimination of Subpart D) affected the plaintiff in a personal way. Cf.

Davis v. Colerain Township, 2022 WL 4351074, at *4 (6th Cir. Sept. 20, 2022). For its first two

theories, Polyweave did not even attempt to make this showing.

With these theories, Polyweave instead focused only on the concrete-injury element.

It essentially claims that the government’s failure to disclose exculpatory evidence in agency

proceedings is a concrete injury because it qualifies as a “harm[] specified by the Constitution”

under Brady. TransUnion, 141 S. Ct. at 2204. Even if this harm did not rise to the constitutional

level, Polyweave adds, it is still concrete because a right to exculpatory evidence in agency

proceedings resembles Brady’s right and so “has a ‘close relationship’ to a harm ‘traditionally’

recognized as” sufficient. Id. (quoting Spokeo, 578 U.S. at 341). Yet I need not decide whether

these arguments suffice to allege a concrete injury. Plaintiffs must establish both concrete and

particularized injuries. See TransUnion, 141 S. Ct. at 2206 n.2 (citing Spokeo, 578 U.S. at 339–

40). And the Secretary’s rescission of Subpart D—by itself—did not injure Polyweave in a

personal way.

I add one final disclaimer about these two theories. On appeal, the parties spend pages

debating the merits of Polyweave’s claims. For the first theory, for example, they dispute

whether we should transplant Brady’s due-process rule from criminal prosecutions to agency

proceedings. The government argues that Polyweave lacks standing because courts have not

extended Brady in this way. Yet this debate is beside the point now because it “conflate[s] the

merits of [Polyweave’s Brady] claim with [Polyweave’s] standing to bring it.” CHKRS, LLC v.

City of Dublin, 984 F.3d 483, 489 (6th Cir. 2021). As long as Polyweave’s claim is not

frivolous, its standing to raise the claim does not depend on our agreement that Brady should

extend to agency proceedings. See id. Polyweave’s standing instead turns on whether it has

identified a concrete and particularized injury. Its first two theories fail because Polyweave does

not allege a particularized injury.

Theories Three and Four. Polyweave’s other theories attempt to rectify this particularity

problem by pointing to its own enforcement proceeding. But these theories suffer from distinct

causation and redressability problems. See Davis, 2022 WL 4351074, at *3. As for causation, a

plaintiff must plausibly plead that its injury is “fairly traceable” to the defendant’s conduct that it

challenges. California v. Texas, 141 S. Ct. 2104, 2113 (2021). So when a plaintiff challenges

one law, it cannot rely on an injury caused by another one. See Davis, 2022 WL 7199288, at *3.

As for redressability, a plaintiff must show that the relief that it requests would remedy the injury

that it alleged. See DaimlerChrysler Corp. v. Cuno, 547 U.S. 332, 353 (2006). Damages can

remedy a past injury, but they do nothing to redress a future one. See Uzuegbunam v.

Preczewski, 141 S. Ct. 792, 798–802 (2021); City of Los Angeles v. Lyons, 461 U.S. 95, 105–10

(1983). Conversely, injunctive and declaratory relief can remedy a future injury, but they do

nothing to redress a past one. See Shelby Advocs. for Valid Elections v. Hargett, 947 F.3d 977,

981 (6th Cir. 2020) (per curiam); Frost v. Sioux City, 920 F.3d 1158, 1161–62 (8th Cir. 2019).

Polyweave’s third theory of injury flunks the causation element. Polyweave’s complaint

(if read charitably) alleged that PHMSA had been failing to disclose exculpatory evidence in its

own enforcement proceeding. This allegation may well plead an Article III injury, but I need not

decide the issue. The complaint failed to plausibly plead that this injurious nondisclosure had

been “fairly traceable” to the Secretary’s rescission of Subpart D (rather than to, say, a rogue

employee or simple incompetence). California, 141 S. Ct. at 2113 (citation omitted). To begin

with, the Secretary’s rationale for the rescission did not suggest that he was doing away with the

agency’s policy of disclosing exculpatory evidence. Rather, he suggested that he rescinded the

regulations for a cosmetic reason: the Department need not codify internal processes in the Code

of Federal Regulations. See 86 Fed. Reg. at 17,293. In addition, the Brady regulation that

Polyweave now seeks to resuscitate existed while it litigated its own enforcement proceeding in

the first instance prior to appealing. So, according to Polyweave, PHMSA was failing to disclose

evidence even before the Secretary rescinded the Brady regulation and during the entire time that

this regulation required that disclosure. How could the Secretary’s later-in-time rescission have

caused the earlier lack of disclosure? The Latin phrase “post hoc ergo propter hoc” describes the

logical fallacy that a later event was caused by an earlier one simply because it came later. To

state a claim here, however, Polyweave must rely on an even more incredible logical leap: “ante

hoc ergo propter hoc.” Simply put, it is implausible to suggest that the Secretary’s rescission

caused any nondisclosure in Polyweave’s proceeding.

Polyweave’s fourth theory of injury flunks the redressability element. Polyweave’s

complaint alleged that it suffered “pocketbook” harms as a result of the rescission of Subpart D.

Polyweave allegedly had to pay its counsel to request that PHMSA disclose the exculpatory

evidence that the prior Brady regulation would have compelled the agency to disclose on its own.

Yet Polyweave sought only injunctive and declaratory relief against the rescission of Subpart D;

it did not seek damages. So this claimed monetary injury in the past does nothing to establish its

standing to seek the remedy that it wants now: an injunction and declaratory relief to redress a

future harm. See Lyons, 461 U.S. at 105–10; Shelby Advocs., 947 F.3d at 981.

For these reasons, I concur in the judgment.

Case Details

Case Name: Polyweave Packaging, Inc. v. Peter Buttigieg
Court Name: Court of Appeals for the Sixth Circuit
Date Published: Oct 20, 2022
Citations: 51 F.4th 675; 21-5929
Docket Number: 21-5929
Court Abbreviation: 6th Cir.
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