Data Marketing Partnership v. LABR, No. 20-11179 (5th Cir. 2022)Annotate this Case
This ERISA case presented the Fifth Circuit with three questions:
1.) Whether the Department of Labor’s self-labeled “advisory opinion” is reviewable “final agency action” under the Administrative Procedure Act;
2.) Whether the Department’s action is arbitrary, capricious, or otherwise contrary to law; and
3.) Whether the district court issued the appropriate relief.
Answering the first two questions in the affirmative, the Fifth Circuit affirmed the district court’s vacatur of the agency action but vacated and remanded the district court’s injunction for further consideration in light of this opinion.