Recent Business Law Cases: Chevron, FTC Non-Competes, and SEC Rulings

Federal courts handed down a cluster of recent business law cases in 2024 and 2025 that pulled authority away from regulatory agencies and reopened rules many companies had long treated as settled. The Supreme Court ended the 40-year practice of deferring to agency interpretations of statutes, extended the time frame for challenging old regulations, and forced the SEC to take penalty cases to a jury. Lower courts struck down the FTC’s nationwide non-compete ban and the Department of Labor’s new overtime salary threshold, and FinCEN walked away from applying the Corporate Transparency Act to domestic companies. Here’s what each ruling changed and what it means for the way you run a business today.

Courts No Longer Defer to Federal Agencies

The most consequential ruling is Loper Bright Enterprises v. Raimondo, 603 U.S. ___ (2024), which overturned Chevron deference. For four decades, when Congress wrote an ambiguous statute and an agency filled in the gaps, judges had to accept the agency’s reading as long as it was reasonable. That is no longer the rule.1Supreme Court of the United States. Loper Bright Enterprises v. Raimondo

The Court held that the Administrative Procedure Act requires judges to use their own independent judgment about what a statute means. When a business now challenges a regulation, the court does a fresh read of the statute instead of giving the agency’s lawyers a built-in head start. Every federal regulator is affected, from the EPA to the SEC to the Department of Labor. Agencies can still interpret statutes, but their interpretations carry no special weight in court.

Longer Window to Challenge Old Regulations

In Corner Post, Inc. v. Board of Governors of the Federal Reserve System, 603 U.S. ___ (2024), the Supreme Court addressed when the six-year statute of limitations starts running for lawsuits brought under the Administrative Procedure Act.2Supreme Court of the United States. Corner Post Inc. v. Board of Governors of the Federal Reserve System

Many courts used to start the clock when the agency finalized the rule, which meant any regulation older than six years was effectively immune. The Court rejected that approach. The clock now starts when a specific plaintiff is actually injured. A business that opens its doors today can challenge a rule from the 1990s if it causes harm now. Pair that with Loper Bright, and long-tolerated agency rules are newly exposed, with no judicial thumb on the scale favoring the agency.

FTC Non-Compete Ban Struck Down

The Federal Trade Commission’s rule banning most non-compete clauses nationwide is dead. In Ryan, LLC v. FTC (No. 3:24-cv-00986), the Northern District of Texas granted summary judgment to the challengers, holding that the FTC exceeded its statutory authority. The court found the Federal Trade Commission Act does not give the agency the power to issue broad substantive rules about unfair methods of competition, and it also found the rule arbitrary and capricious.3Justia. Ryan LLC v. Federal Trade Commission, No. 3:2024cv00986 Rather than limit the injunction to the parties, the court set the rule aside entirely. The FTC voted 3-1 on September 5, 2025, to dismiss its appeals and formally accept the vacatur.4Federal Trade Commission. Federal Trade Commission Files to Accede to Vacatur of Non-Compete Clause Rule

The federal ban is gone, but non-competes still face pressure from the states. Four states ban them outright, and more than 30 others impose significant restrictions, often tied to income thresholds. If you use non-competes across multiple states, you need to check each one.

Corporate Transparency Act Reporting All But Gone for U.S. Companies

The Corporate Transparency Act, codified at 31 U.S.C. ยง 5336, required millions of small businesses to report beneficial owner information to Treasury’s Financial Crimes Enforcement Network. Multiple lawsuits attacked the law, and the result for domestic companies is effectively no reporting obligation.

In National Small Business United v. Yellen (No. 5:22-cv-01448), the Northern District of Alabama held that the CTA exceeds Congress’s constitutional authority. The court found that forming a business under state law does not substantially affect interstate commerce and that the reporting mandate is not a valid taxing-power exercise because its purpose is not revenue collection.5Justia. National Small Business United et al v. Yellen et al The Justice Department appealed.6Financial Crimes Enforcement Network. Updated Notice Regarding National Small Business United v. Yellen, No. 5:22-cv-01448 (N.D. Ala.) A separate case, Texas Top Cop Shop, Inc. v. Garland, produced a nationwide preliminary injunction in December 2024 that shelved the original January 1, 2025, reporting deadline.

FinCEN then conceded the point for domestic businesses. In an interim final rule published in March 2025, the agency redefined “reporting company” to include only entities formed under foreign law that have registered to do business in the United States. All companies created under U.S. state law are exempt, and FinCEN said it will not enforce penalties against U.S. citizens or domestic companies.7Financial Crimes Enforcement Network. FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons Foreign entities registered to do business in the U.S. still have a 30-day reporting window from registration. The constitutional cases remain pending, but domestic companies have no filing obligation right now.

Overtime Salary Threshold Reverted

The Department of Labor’s 2024 rule raising the salary threshold for the white-collar overtime exemption was vacated by the Eastern District of Texas on November 15, 2024. The rule would have taken the minimum salary to $58,656 per year by January 2025. The enforceable threshold reverted to the 2019 level: $684 per week, or $35,568 per year.8U.S. Department of Labor. Earnings Thresholds for the Executive, Administrative, and Professional Exemptions

Salary is only half the test. To classify a worker as exempt, you also have to pay on a true salary basis (a fixed amount that doesn’t fluctuate with hours worked) and confirm the employee’s primary duties qualify under the executive, administrative, or professional tests.9U.S. Department of Labor. Fact Sheet – Exemption for Executive, Administrative, Professional, Computer and Outside Sales Employees Under the Fair Labor Standards Act Employers who raised salaries in anticipation of the higher threshold do not have to roll them back, but they are not required to maintain the increase either. Some states set higher thresholds, and when state and federal rules conflict, the rule more favorable to the employee controls.

SEC Must Use Jury Trials for Penalty Cases

The SEC long used its own in-house administrative law judges to impose civil penalties in securities fraud cases. In SEC v. Jarkesy, 603 U.S. 109 (2024), the Supreme Court held that practice violates the Seventh Amendment right to a jury trial. When the SEC seeks civil penalties for securities fraud, the defendant is entitled to a jury in federal court.10Supreme Court of the United States. SEC v. Jarkesy

That is a significant loss of home-court advantage for the agency. Administrative proceedings gave the SEC favorable procedural rules, limited discovery, and agency-employed judges. Federal court brings broader discovery, the Federal Rules of Evidence, and a jury. The ruling also opens the door to similar Seventh Amendment challenges against other federal agencies that impose civil penalties in-house.

Lower Bar for Title VII Transfer Claims

In Muldrow v. City of St. Louis, 601 U.S. 346 (2024), the Supreme Court rejected the rule many lower courts had used requiring employees to prove a “significant” disadvantage or material harm from a discriminatory job transfer. The actual standard under Title VII is simpler: the employee only needs to show the transfer caused some harm to the terms or conditions of employment.11Supreme Court of the United States. Muldrow v. City of St. Louis

The word “some” is doing real work. An employee moved to a less desirable schedule, stripped of a specialized assignment, or given less meaningful responsibilities can bring a Title VII claim even if salary and title stayed the same. Before Muldrow, that injury was often dismissed as too minor. For employers, transfer decisions now need the same documentation and legitimate business justification you would apply to hiring and firing. A lateral move that looks neutral on paper can produce liability if the real motivation was discriminatory.

SEC Climate Disclosure Rules Left Undefended

The SEC adopted rules in 2024 requiring public companies to disclose climate-related risks and greenhouse gas emissions, with phased compliance beginning in 2026 for the largest filers. The rules drew legal challenges from industry groups that called them overreach and from environmental advocates who said they didn’t go far enough. The consolidated cases landed in the Eighth Circuit, and the SEC stayed the rules while litigation proceeded.12Securities and Exchange Commission. SEC Votes to End Defense of Climate Disclosure Rules

In 2025, the SEC voted to stop defending the rules and withdrew its legal arguments. The Eighth Circuit placed the litigation in abeyance, leaving the agency the choice to start a new rulemaking or resume the defense. For now, there is no federal climate disclosure mandate for public companies. Firms that had started building compliance infrastructure are in a holding pattern.