In an 8-1 decision written by Chief Justice Roberts, the Supreme Court reversed the Fifth Circuit and held that FCC forfeiture orders do not violate the Seventh Amendment when issued without a jury, because they do not create a binding obligation to pay — any collection requires a subsequent de novo jury trial before an Article III court. The case involved over $100 million in FCC fines imposed on AT&T and Verizon for sharing customer location data without adequate vetting of third parties. The Court distinguished the FCC’s scheme from the SEC’s enforcement structure struck down in Jarkesy (2024), since the FCC cannot execute on a forfeiture order unilaterally: only the DOJ can collect through a separate jury trial. The ruling limits the reach of Jarkesy and confirms the constitutionality of similar two-step administrative enforcement schemes.
