Texas Tobacco Barn v. Department of Health and Human Services

In Texas Tobacco Barn, L.L.C. v. HHS, the United States Court of Appeals for the Fifth Circuit addressed whether federal agencies can impose civil penalties without a jury trial. The court vacated a $19,192 fine against a vape manufacturer, ruling that the administrative proceeding violated the Seventh Amendment. While the court upheld the FDA's legal authority to regulate e-cigarettes, it determined that the public-rights exception did not apply to these enforcement actions. The majority found that the penalties were punitive in nature and analogous to common-law suits that traditionally require a jury. Conversely, the dissenting opinion argued that the premarket authorization process is a novel regulatory scheme that falls within the executive's power to manage interstate commerce and public health. This ruling reinforces Article III judicial protections by limiting the government's ability to bypass juries through agency adjudications.