Economy February 24, 2026

Appeals Court Pushes Back as Administration Seeks to Remove CFPB Workforce

Judges probe whether federal courts can bar mass firings at the Consumer Financial Protection Bureau as litigation continues over agency’s future

By Hana Yamamoto
Appeals Court Pushes Back as Administration Seeks to Remove CFPB Workforce

A full panel of the U.S. Court of Appeals for the D.C. Circuit questioned the Trump administration’s contention that federal courts lack authority to prevent large-scale dismissals of staff at the Consumer Financial Protection Bureau (CFPB). The CFPB has been largely inactive since last February while the administration pursues court approval to drastically reduce or eliminate its workforce; officials attempted such cuts twice. At a hearing, government lawyers argued that challenges should proceed through the Merit Systems Protection Board, even as judges pressed on jurisdiction and the administration’s broader intentions.

Key Points

  • A full 11-judge panel of the D.C. Circuit scrutinized the administration's claim that federal courts cannot prevent mass firings at the CFPB.
  • The CFPB has been largely inactive since February of last year while the administration sought to reduce or eliminate its workforce; officials attempted the cuts twice.
  • Legal questions include whether employees must pursue challenges at the Merit Systems Protection Board and whether the lower court correctly found the government intended to shut down the agency - issues with implications for financial regulation and federal labor processes.

Judges on the U.S. Court of Appeals for the District of Columbia Circuit pressed the Trump administration on Tuesday over its claim that federal courts cannot block the government from dismissing most employees at the Consumer Financial Protection Bureau (CFPB).

The consumer watchdog has been largely on ice since February of last year while the administration seeks judicial clearance to decimate, if not eliminate, its staff - moves officials tried to carry out on two occasions. While top administration figures have publicly argued for eliminating the CFPB as a politicized obstacle to free enterprise, in court the government has asserted it does not plan to do so.

The matter was argued before the court’s full 11-judge bench, where Deputy Assistant Attorney General Eric McArthur faced sustained questioning over the government’s position that a lower court overstepped when it enjoined the proposed mass firings and concluded the administration intended to shut the agency down.

At the hearing, McArthur told the panel that employees should pursue claims before the Merit Systems Protection Board (MSPB), the specialized labor forum traditionally used to contest federal firings. He also acknowledged that the administration does not possess the authority to abolish the CFPB outright, because Congress has mandated the agency’s existence.

Judge Cornelia Pillard highlighted the stakes of the lower court’s factual finding about the government’s intent, asking: "If we were to affirm the district court's finding that the government intended to shut down the agency, that changes the landscape doesn't it?"

McArthur emphasized the executive branch's obligation to follow the law but cautioned that "courts do not have unbridled authority to enforce that obligation." Separately, the administration is pursuing measures to weaken the MSPB's power to review government decisions.

Jennifer Bennett, counsel for a union representing CFPB employees who sued to block the administration’s actions, told the judges that Congress did not design the MSPB to resolve constitutional separation-of-powers questions. She framed the union's claim as broader than an individual wrongful termination grievance: "The claim here is not 'I shouldn't have been laid off'... but 'this agency should not have been shut down,'" she said. "I heard the defendants admit that that claim can proceed in court."

The case has a complex procedural history. In August, a three-judge panel at the appeals court overturned the lower court by finding it lacked jurisdiction to intervene. Later, the court's full bench in December reinstated the lower court's injunction and agreed to rehear the jurisdictional and substantive questions now before it.


This set of proceedings will determine where disputes over sweeping personnel actions at an independent consumer regulator can be litigated - in federal court or before the MSPB - and whether the lower court's finding about the government's intent to shutter the agency is binding as the litigation moves forward.

Risks

  • Uncertainty over judicial jurisdiction - whether federal courts can block mass firings or whether the MSPB is the exclusive forum - creates legal ambiguity for federal employees and regulators, affecting the financial regulatory sector.
  • The administration's parallel efforts to weaken the MSPB's review power introduce risk that employee remedies and oversight of personnel actions could be constrained, with potential consequences for enforcement continuity at regulatory agencies.
  • Conflicting court rulings to date - a split panel decision in August and a full-bench reinstatement in December - mean the legal path remains unsettled, prolonging operational uncertainty at the CFPB and surrounding regulatory enforcement.

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