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NFIB v. Yellen Court Documents

NFIB v. Yellen Court Documents — Anonymousllc.co's 2026 reference. Covers the rule, the controlling statute or regulation, common questions, and how Anonymousllc.co handles it in practice. Primary-source citations linked throughout.

By Alif Al Razi, Tax & Compliance Lead · Last updated 2026-05-21
Primary source — U.S. District Court for the Northern District of Alabama
NFIB v. Yellen — N.D. Ala. 5:22-cv-1448

March 1, 2024 ruling by Judge Liles Burke. Held the Corporate Transparency Act facially unconstitutional as exceeding Congress's enumerated powers.

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NFIB v. Yellen — what the court held

On March 1, 2024, Judge Liles Burke of the Northern District of Alabama ruled the Corporate Transparency Act (31 USC § 5336) facially unconstitutional, holding that it exceeded Congress's enumerated powers under the Commerce Clause, the Necessary and Proper Clause, and Congress's taxing power. The ruling enjoined enforcement against the named plaintiffs (NSBA members) but did NOT extend nationwide.

Sources
  • NFIB v. Yellen — 5:22-cv-1448 ruling — March 1, 2024

Background

The National Small Business Association (NSBA) and several individual plaintiffs sued the Treasury Department and FinCEN in November 2022, challenging the CTA on multiple constitutional grounds: enumerated-powers limits, First Amendment associational rights, Fourth Amendment privacy, Fifth Amendment due process and self-incrimination. The court reached the enumerated-powers question first and stopped there.

Holding — enumerated powers

The court held that the CTA cannot be sustained under: (1) the Commerce Clause, because forming a corporation is not interstate commerce; (2) the Necessary and Proper Clause, because no specifically enumerated power justifies the regulation; (3) the taxing power, because the CTA is not a tax. The result: the CTA was unconstitutional on its face for the plaintiffs.

Scope — plaintiffs only

The injunction protected only the NSBA, its individual member plaintiff, and members of the NSBA as of March 1, 2024. It did NOT extend nationwide. Non-NSBA-member small businesses still had to comply pending appeal or further rulings.

Eleventh Circuit appeal

Treasury and FinCEN appealed to the Eleventh Circuit. Oral argument occurred September 27, 2024. As of the March 2025 FinCEN Interim Final Rule, the appeal became less consequential — FinCEN administratively exempted domestic reporting companies, mooting much of the dispute for the affected class.

Impact on the CTA's trajectory

NFIB v. Yellen was the first major federal court ruling to strike down the CTA. It was followed by Texas Top Cop Shop v. Garland (E.D. Tex., Dec. 3, 2024) which issued a NATIONWIDE preliminary injunction. The combination of NFIB v. Yellen and Texas Top Cop Shop drove Treasury's decision to issue the March 2025 IFR exempting domestic reporting companies.

Sources
  • Texas Top Cop Shop v. Garland — nationwide injunction
  • FinCEN March 2025 IFR (90 FR 13688)

Authority sources

Government, regulator, and primary-source documents underpinning this page.

CourtListener
NFIB v. Yellen — N.D. Ala. 5:22-cv-1448 (Mar. 1, 2024)
https://www.courtlistener.com/docket/65586036/national-small-business-united-v-yellen/
CourtListener
Texas Top Cop Shop v. Garland — E.D. Tex. 4:24-cv-478
https://www.courtlistener.com/docket/68413412/texas-top-cop-shop-inc-v-garland/
SCOTUS
McHenry v. Texas Top Cop Shop — SCOTUS 24A653 stay order (Jan. 23, 2025)
https://www.supremecourt.gov/search.aspx?filename=/docket/docketfiles/html/public/24a653.html
Cornell LII
31 USC § 5336 (Corporate Transparency Act)
https://www.law.cornell.edu/uscode/text/31/5336
Federal Register
FinCEN March 2025 Interim Final Rule (90 FR 13688)
https://www.federalregister.gov/documents/2025/03/26/2025-05199/

Related resources

BOI Key Dates Timeline 2024-2026
/resources/boi-key-dates/
FinCEN Final Rule (31 CFR 1010.380)
/resources/fincen-final-rule/
Supreme Court Stay on CTA Enforcement
/resources/scotus-cta-stay/

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