D.C. Circuit Limits Prohibition On CFPB Staff Terminations Pending Appeal

In a per curiam order, a three-judge panel of the U.S. Court of Appeals for the District of Columbia Circuit on April 11, 2025, partially stayed a preliminary injunction halting any attempt to dismantle the CFPB. Judges Cornelia Pillard, Gregory Katsas and Neomi Rao limited the scope of U.S. District Court for the District of Columbia Judge Amy Berman Jackson's March 28 preliminary injunction but allowed several remaining provisions to remain intact.

Judge Jackson's preliminary injunction (on which Holland & Knight previously reported) required the CFPB to reinstate all terminated employees and refrain from further terminations or reductions in force (RIFs) until claims against the CFPB were fully resolved. As also previously reported by Holland & Knight, the D.C. Circuit stayed these provisions insofar as they require to reinstate or prohibit the termination of employees "unnecessary to the performance of [the CFPB's] statutory duties." The remaining provisions of