Supreme Court Stay on CTA Enforcement — 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.
Supreme Court order staying the Fifth Circuit's affirmance of the Texas Top Cop Shop nationwide injunction pending Treasury's appeal.
Open full text →On January 23, 2025, the U.S. Supreme Court granted Treasury's application for a stay in McHenry v. Texas Top Cop Shop (24A653). The stay paused the nationwide preliminary injunction issued by the E.D. Tex. court that had halted BOI enforcement against ALL reporting companies. The stay was procedural — it allowed Treasury to enforce the CTA pending appeal but did not rule on the constitutional merits.
On December 3, 2024, Judge Amos Mazzant of the E.D. Tex. issued a NATIONWIDE preliminary injunction halting all CTA enforcement. The Fifth Circuit briefly stayed the injunction, then reinstated it. Treasury sought emergency relief at the Supreme Court. The Court granted the stay 8-1 (Justice Jackson dissenting).
The SCOTUS stay theoretically reinstated CTA enforcement nationwide. In practice, a SEPARATE injunction from the National Small Business United v. Yellen case continued to bar enforcement against NSBA members, and FinCEN announced it would not enforce against any reporting company pending further proceedings. The stay's practical effect was muted.
Within two months of the stay, FinCEN issued the March 2025 Interim Final Rule (90 FR 13688) exempting domestic reporting companies from BOI reporting entirely. The SCOTUS stay became moot for US LLCs — the rule change accomplished administratively what the courts could not on a national scale.
The stay confirmed two things: (1) the Supreme Court was not yet ready to address the CTA's constitutional merits; (2) the political pressure on Treasury was sufficient that FinCEN moved to a regulatory solution rather than rely on continued litigation. For LLC owners, the practical takeaway is that BOI was effectively ended for US domestic companies regardless of how the court fight resolved.
Your US LLC is exempt from BOI reporting under the March 2025 IFR. The SCOTUS stay is a historical reference point — it does not currently impose any filing obligation on your Anonymousllc.co Wyoming, New Mexico, Delaware, or Nevada LLC. If you formed a foreign reporting company, separate filing rules apply.
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