LIGADO NETWORKS LLC v. US

Federal CircuitMar 9, 2026

Split Score

SplitScore: 40/100

Case Summary

Disposition

Affirmed in Part

The Federal Circuit (treated here as the 13th Circuit) reviewed an interlocutory order in Ligado’s Tucker-Act takings suit arising from an FCC spectrum license. It affirmed the Court of Federal Claims on jurisdiction and authorization, but vacated and remanded on whether the license confers a Takings-Clause-protected property right and on the nature of any physical taking. The panel left open key merits questions and sent the case back for further development.

View Full Opinion Document (PDF)

Circuit Split Identified

Legal Issue

Whether the term "order" in 47 U.S.C. § 401(b) encompasses FCC rules and regulations adopted through notice-and-comment rulemaking, thereby allowing private parties to sue for their enforcement.

Circuit Positions

Circuit 1

§ 401(b) "order" does NOT include FCC rules; private enforcement limited to specific adjudicatory orders.

Circuit 3Circuit 9

§ 401(b) "order" DOES include FCC rules and regulations, allowing private parties to seek injunctions for rule violations.

Federal Circuit(this circuit)

Question undecided – circuit acknowledges split but takes no position.

Conflict Summary

The First Circuit has held that § 401(b) actions may be brought only to enforce discrete Commission orders and not agency rules, while the Ninth and Third Circuits have concluded that Commission rules can qualify as "orders" for § 401(b) purposes. The present (13th) Circuit opinion acknowledges the disagreement but expressly declines to adopt either reading, leaving the question open within this circuit.

Parties & Counsel

Parties

Appellant:United States
Appellee:Ligado Networks LLC

Legal Counsel

Appellant:Nathanael Yale, Commercial Litigation Branch, Civil Division, U.S. Department of Justice (with Borislav Kushnir, Patricia M. McCarthy, and Brett Shumate)
Appellee:Donald B. Verrilli, Jr., Munger, Tolles & Olson LLP (with Ginger Anders, Evan J. Mann, David Coon, Yelena Konanova, Philippe Selendy, Harris Fischman, Martin Flumenbaum, and Kevin F. King)