Verizon Commc’ns Inc. v. Fed. Commc’ns Comm’n

2nd CircuitSep 10, 2025

Split Score

SplitScore: 38/100

Case Summary

Disposition

Affirmed

Verizon petitioned for review of an FCC order imposing a $46.9 million forfeiture for failing to safeguard customer-location data in violation of 47 U.S.C. § 222. The Second Circuit held that device-location data is protected customer proprietary network information, the FCC’s liability and penalty determinations were reasonable and within statutory caps, and Verizon’s Seventh Amendment argument failed because it could have demanded a jury in a § 504(a) collection action. The court therefore denied the petition and affirmed the FCC’s order.

Circuit Split Identified

Legal Issue

Whether, in an FCC forfeiture collection action under 47 U.S.C. § 504(a), the district court’s “trial de novo” permits the defendant to raise statutory‐interpretation and constitutional challenges to the underlying forfeiture order, or whether such challenges are exclusively within the jurisdiction of the courts of appeals under 47 U.S.C. § 402(a) and the Hobbs Act.

Circuit Positions

2nd Circuit(this circuit)

Section 504(a) affords a true trial de novo in which the defendant may litigate statutory and constitutional challenges to the forfeiture order.

5th Circuit

District courts conducting a § 504(a) action cannot consider legal or constitutional challenges; review of such questions is exclusive to the courts of appeals under § 402(a)/Hobbs Act.

Conflict Summary

The Second Circuit holds that the statutory command of a "trial de novo" in § 504(a) authorizes a district court to consider both factual and legal challenges—including constitutional claims—because the proceeding starts "afresh." The Fifth Circuit, in United States v. Stevens, 691 F.3d 620 (5th Cir. 2012), held the opposite: that district courts lack jurisdiction to revisit legal questions already decided by the FCC because exclusive jurisdiction lies with the courts of appeals under the Hobbs Act.

Parties & Counsel

Parties

Appellant:Verizon Communications Inc.
Appellee:Federal Communications Commission (and United States of America)

Legal Counsel

Appellant:Kellogg, Hansen, Todd, Figel & Frederick, PLLC (Scott H. Angstreich, Aaseesh P. Polavarapu)
Appellee:Federal Communications Commission – Scott M. Noveck (with P. Michele Ellison, Jacob M. Lewis, Sarah E. Citrin); U.S. Department of Justice – Doha G. Mekki, Robert B. Nicholson, Matthew A. Waring

Opinion Document