"If the CTA is allowed to go into effect, the Plaintiffs-Appellees and all state-registered corporate entities, not the Government Defendants, will suffer irreparable harm."
“Refusing to permit the collateral review of Seventh Amendment claims under Axon will subject numerous respondents in administrative adjudications of common law claims to unconstitutionally structured, juryless processes.”
"Section 1733 of the Federal Land Policy and Management Act (FLPMA) confers expansive criminal lawmaking power on the Secretary of the Interior in violation of the Constitution, allowing the Secretary, acting through the Bureau of Land Management (BLM), to create a criminal code applicable over a significant part of the country and a majority of the state of Nevada."
"This case is the ideal vehicle for revitalizing the nondelegation doctrine because the OSH Act represents, arguably, the broadest delegation by Congress to the Executive Branch since the NIRA."