D.C. Circuit Rejects Immediate CFPB Layoffs, Sends Revised Restructuring Plan to District Court for Expedited Review
In a major procedural showdown over the future of the Consumer Financial Protection Bureau (CFPB), the en banc U.S. Court of Appeals for the District of Columbia Circuit issued an order on June 19, 2026, denying the Trump administration's request to immediately liftoff the preliminary injunction and proceed with massive job cuts123.4 Instead, the court granted a limited remand to U.S. District Judge Amy Berman Jackson to evaluate whether a newly revised "Workforce Restructuring Plan" (WRP) submitted by Acting CFPB Director Russell Vought warrants modifying or dissolving her existing injunction.5
Under the revised WRP, the administration plans to slash the CFPB's workforce by over 50%, reducing staffing from approximately 1,174 employees to 556 employees. This is a partial scale-back from an earlier proposal that would have eliminated 90% of the agency's workforce. The administration argues that the new plan would still permit the Bureau to perform its "core statutory functions" under the drastically reduced funding levels mandated by the One Big Beautiful Bill Act (OBBBA), which halved the CFPB's statutory funding cap from the Federal Reserve.
Judge Jackson, who has repeatedly warned that the administration cannot unilaterally dismantle an agency established by Congress, moved with extreme speed on the remand.6 On June 22, 2026, she issued a scheduling order directing the parties to immediately identify available dates for expedited proceedings.
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An instance of You cannot dismantle federal agencies or programs through unilateral executive underfunding and administrative shifts. — The federal court blocked immediate unilateral layoffs at the CFPB, forcing the administration to submit its restructuring plans to judicial review. ↩︎
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An instance of Legislative budget caps cannot be leveraged as executive mandates to unilaterally dismantle federal programs. — The D.C. Circuit refused to allow the administration to use legislative budget cap reductions as an executive mandate to execute immediate staff layoffs. ↩︎
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An instance of Executive workarounds to dissolve federal departments trigger immediate state lawsuits and legislative blockades. — The federal court system blocked the administration's rapid procedural maneuvers to downsize and dissolve an agency established by Congress. ↩︎
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An instance of Unilateral executive efforts to withhold, redirect, or bypass legislatively mandated program funding face swift judicial blocks. — It shows federal appellate courts maintaining preliminary injunctions against executive workforce cuts that seek to bypass Congress's statutory mandates. ↩︎
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An instance of Executive workarounds to dissolve federal departments trigger immediate state lawsuits and legislative blockades. — Unilateral plans to slash agency workforce capacities by 90% are tied up and blocked in federal court reviews. ↩︎
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An instance of Unilateral executive branch restructurings dissolve the moment they face bipartisan legislative blockades. — The federal courts and congressional statutes restrict the administration from unilaterally slashing the CFPB's workforce beyond its core statutory functions. ↩︎