Gwynne A. Wilcox v. Donald J. Trump

DC CircuitDec 5, 2025

Split Score

SplitScore: 54/100

Case Summary

Disposition

Reversed

In consolidated appeals, the 12th Circuit held that statutory ‘for-cause’ removal protections for members of the National Labor Relations Board and the Merit Systems Protection Board violate Article II because both agencies wield substantial executive power. Accordingly, the court reversed district-court judgments that had reinstated two ousted board members, declaring the President may remove them at will.

View Full Opinion Document (PDF)

Circuit Split Identified

Legal Issue

Whether the National Labor Relations Board possesses statutory authority under 29 U.S.C. § 160(c) to award compensatory or consequential-like monetary damages as affirmative relief for unfair-labor-practice violations.

Circuit Positions

Circuit 5DC Circuit(this circuit)

Section 160(c) authorizes the NLRB to award compensatory and consequential damages as part of its affirmative remedial powers.

Circuit 3

Section 160(c) does not authorize the NLRB to award such monetary damages; any order granting them is ultra vires.

Conflict Summary

Some circuits read § 160(c) broadly to permit the NLRB to order compensatory and consequential damages ‘to effectuate the policies of the Act,’ while others hold that such monetary relief exceeds the Board’s statutory remit and is ultra vires.

Parties & Counsel

Parties

Appellant:Scott Bessent (Secretary of the Treasury) and Donald J. Trump (President of the United States), et al.
Appellee:Cathy A. Harris and Gwynne A. Wilcox

Legal Counsel

Appellant:Harry Graver, Eric D. McArthur, Mark R. Freeman, Michael S. Raab, Joshua M. Salzman, Laura E. Myron, Daniel Aguilar – U.S. Department of Justice
Appellee:Nathaniel A. Zelinsky (for Harris) and Deepak Gupta (for Wilcox), with Michael J. Kator, Jeremy D. Wright, Kerrie D. Riggs, Linda M. Correia, Neal K. Katyal, Jennifer D. Bennett, Matthew W. H. Wessler, Gregory A. Beck, Alisa C. Philo, et al.