Circuit Scoop: January 2025

January 2025 brought pivotal federal appeals court rulings that challenge agency power, shape business regulations, and influence constitutional law, with long-lasting effects on future legal battles

The 2021 decision in BST Holdings, L.L.C. v. Occupational Safety and Health Administration, United States Department of Labor (CA5) marked a significant moment in the ongoing debate over the reach of federal agency powers and the powers that define these agencies in varying degrees of exigent circumstances. In this case, the Fifth Circuit Court of Appeals ruled against the Occupational Safety and Health Administration (OSHA) vaccine mandate, citing the lack of clear congressional authorization for such sweeping regulatory measures during the Covid-19 pandemic. The court's ruling emphasized that “an agency’s power is not unlimited,” reinforcing the principle that federal agencies must act within the bounds of authority granted by Congress, rather than expanding their powers through broad or ambiguous interpretations of existing laws (sound like a Supreme Court decision?) This decision highlights the oversized role that federal appeals courts play in defining geographically specific and sometimes national policies along with the essential part they play in defining balance of power between the judiciary, the executive, and the legislative branches of government.

This article explores key federal appeals courts decisions during January 2025, oftentimes specifically highlighting the complexities of judicial interpretation in areas such as regulatory authority, insurance law, and copyright protections. A recurring theme is the court’s role in defining ambiguous legal terms, especially when agencies or parties fail to do so. In some cases, courts have questioned the validity of regulations based on unfounded premises, while others focus on the disruptive effects of vacating rules that could impact settled systems. This highlights the federal appeals courts’ nuanced approach in balancing the need for fair enforcement with the consequences of regulatory changes, often opting for remand or further briefing to address unresolved issues.

Another critical aspect discussed is the granting of injunctive relief, particularly when potential harm to businesses is at stake. Federal appeals courts have emphasized the importance of evaluating irreparable harm, especially in cases where businesses face substantial financial or reputational damage. Additionally, rulings in copyright law reaffirm the protections for platforms hosting user-generated content under the Digital Millennium Copyright Act, underscoring the limitations of service provider liability. These cases collectively reflect how federal appeals courts navigate the intersection of law, business, and technology, shaping the legal framework that governs industries today.

Why you should care about these decisions

The federal courts of appeals are the lifeblood of the judiciary, serving as the critical bridge between the trial courts and the highest court in the land. These courts wield immense power, interpreting and shaping the law with far-reaching consequences. As the final arbiters on most legal issues, they seemingly ensure that justice is not only done but seen to be done, providing a crucial check on the decisions of district courts. With their vast caseloads, these appellate courts are the gatekeepers of legal precedent, interpreting statutes, refining constitutional doctrines, and upholding the delicate balance of power between government branches. Their decisions resonate well beyond the cases they directly address, influencing future legal battles and the evolution of law itself.

Within the appellate realm, judges are tasked with more than just reviewing lower court rulings—they must navigate complex legal arguments, sift through intricate factual records, and wrestle with nuanced questions of justice and fairness. In this way, the appellate courts are not just legal entities but dynamic forces that continuously refine the meaning of justice and the law itself.

Descriptive Statistics

There are four graphs below that provide a sense of the total output for the federal courts of appeals for January 2025. To begin is a look at the number of decisions per circuit for this period. Note that these are decisions of any length provided by the courts which will become more evident in the second graph.

Even though the Ninth and Fifth Circuits are the two largest by size and generally have the most decisions each month, the Fourth Circuit came out with five more decisions this month than the Ninth Circuit for the most by a circuit in January 2025. The next graph shows the word count distribution across all decisions this past month.

The largest bucket of decisions is the zero-to-500-word range with the second largest bucket between 500 and 1,000 words. The number of opinions per word count range drop off from there with 18 decisions longer than 10,000 words. Now to synthesize the first two graphs, the next graphs looks at the average decision length by circuit.

The smallest circuits, the First and D.C., averaged the lengthiest opinions during this period. They also had the fewest decisions which might play into the word count productivity, but they have fewer judges than the largest circuits, which should even out the output. The Ninth Circuit had the second shortest average opinions at over 100 fewer words on average than the Fourth Circuit’s average decision length which makes the lower decision count for the Ninth even more intriguing.

The last graph breaks the opinions down by day to provide a gauge of the relative opinion release distribution across the month.

The decision pace seemed to pick up speed around the 10^th of January and after a dip, there was the highest points on the 27^th and 28^th of January followed by another dip to end the month.

Top Decisions

To sift out the top ten decisions, ranking was determined by the inclusion of factors such as relative issue importance, decision length, separate opinions, amicus briefs, top ranked firms, potential circuit splits, and repeat player parties involved.

Within the 10 cases the ranking from top to bottom reflects a balance between constitutional significance, regulatory impact, statutory interpretation, precedential value, and societal consequences. Cases involving fundamental rights, agency authority, and broad societal implications were ranked highest, while those with narrower or more technical legal issues were ranked lower. This methodology ensures that the most impactful and precedent-setting decisions were prioritized.

1) Huntsman v. Corporation of the President of the Church of Jesus Christ of Latter-Day Saints

United States Court of Appeals, Ninth Circuit; January 31, 2025

Description: The case involves James Huntsman alleging that the Church of Jesus Christ of Latter-day Saints committed fraud by using tithing funds for commercial ventures, and the en banc court affirmed the district court’s decision, granting summary judgment in favor of the Church, finding no evidence of fraudulent misrepresentation regarding the source of funds for its projects. The court also held that the church autonomy doctrine did not apply since the claims did not involve church doctrine or policy.

Importance: This case addresses the intersection of fraud claims and the First Amendment's church autonomy doctrine. It has significant implications for how courts handle disputes involving religious institutions and their internal financial practices. The decision reinforces the principle that courts should avoid interfering in religious matters, which is a cornerstone of constitutional law.

Impact: The ruling could shield religious organizations from certain legal challenges, particularly those involving financial transparency, and set a precedent for how courts balance fraud claims against First Amendment protections.