Boyle v. Trump (CPSC Comm Fire)
Overview
Overview
Commissioners of the U.S. Consumer Product Safety Commission challenged President Trump's attempt to terminate them from the commission.
The Issue
Issue
Whether the President possesses unilateral authority to remove Commissioners of the Consumer Product Safety Commission without cause.
The Rules
Rule
Under Humphrey's Executor v. United States, 295 U.S. 602 (1935), Congress may restrict the President's removal authority for members of independent agencies by requiring removal only 'for cause.' The CPSC statute provides that commissioners may be removed only for 'inefficiency, neglect of duty, or malfeasance.'
The Application
Analysis
President Trump sought to terminate CPSC Commissioners without demonstrating statutory cause. The commissioners challenged this removal attempt as exceeding the President's constitutional and statutory authority.
The Conclusion
Conclusion
The court upheld the for-cause removal protections for CPSC commissioners, determining that the President lacks authority to terminate them without statutory cause.
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