Boyle v. Trump (CPSC Comm Fire Appeal)
Overview
Overview
President Trump removed three commissioners of the U.S. Consumer Product Safety Commission before their terms ended. Judge Matthew J. Maddox ordered them reinstated, the government appealed, and on September 22, 2026 the Fourth Circuit reversed and allowed the removals to stand.
The Issue
Issue
Whether the President has constitutional or statutory authority to remove Consumer Product Safety Commissioners without cause, or whether the CPSC statute restricts removal to commissioners serving fixed terms only 'for cause.'
The Rules
Rule
The Consumer Product Safety Commission Act protects commissioners by limiting removal to cases of 'for cause.' Courts apply the Humphrey's Executor standard: statutory removal restrictions are constitutional when applied to offices that do not involve core executive policy-making functions.
The Application
Analysis
President Trump terminated three CPSC commissioners mid-term without establishing cause. Judge Matthew J. Maddox reinstated them, holding that the removals violated the agency's statutory for-cause protection. While the government's appeal was pending, the Supreme Court held in Trump v. Slaughter on June 29, 2026 that for-cause removal protection for members of independent multimember agencies like the Federal Trade Commission is unconstitutional. With Slaughter controlling, the Fourth Circuit granted a joint motion for summary reversal on September 22, 2026, reversed the reinstatement order, and remanded for entry of judgment. The commissioners' removal stands.
The Conclusion
Conclusion
On September 22, 2026, the Fourth Circuit granted a joint motion for summary reversal, reversed the district court's order that had reinstated the three Consumer Product Safety Commission members President Trump sought to remove, and remanded the case for further proceedings. The appeal had been held in abeyance pending Trump v. Slaughter, in which the Supreme Court held on June 29, 2026 that for-cause removal protection for members of independent agencies like the Federal Trade Commission is unconstitutional. With Slaughter controlling, the appellees joined the government in seeking summary reversal. The commissioners' removal stands, and the case returns to the district court to enter judgment consistent with the appellate ruling. Judge Heytens entered the order, joined by Judges Gregory and Wynn.
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