BALTIMORE — Despite recent guidance from the United States Supreme Court, a federal district judge in Maryland is ordering President Donald Trump to reinstate three fired members of the United States Consumer Product Safety Commission.
Mary Boyle, Alexander Hoehn-Saric, and Richard Trumka Jr. were each appointed board commissioners under former Democratic President Joe Biden.
Their main duties are to enforce and investigate consumer product safety law compliance.
The board consists of five members appointed by the President of the United States. Congressional rules state no more than three active members of the board can be of the same political party.
Back in May, Boyle, Hoehn-Saric, and Trumka received termination notices, leaving the board with only two Republican members.
Biden appointed judge, Matthew J. Maddox, said the firings were illegal because the trio could only be removed “for neglect of duty or malfeasance in office but for no other cause,” none of which they're accused of.
In his ruling Maddox cites a 1935 Supreme Court case known as Humphrey’s Executor, limiting a sitting President's power to remove certain government board members.
While the Supreme Court's conservative majority has yet to officially overhaul Humphrey’s Executor, a series of recent rulings indicate it may in the near future.
As Trump dismissed Boyle, Hoehn-Saric, and Trumka, individual members of the National Labor Relations and Merit Systems Protection Boards were also relived of their duties.
Both of those members, Gwynne Wilcox and Cathy Harris, sued under the same legal reasoning as Boyle, Hoehn-Saric, and Trumka.
While lower courts sided with Wilcox and Harris, the justices ruled Trump "may remove without cause executive officers who exercise that power on his behalf."
Other lower courts seem to have gotten the message.
For example, earlier this month Judge Richard Leon, in Washington D.C., ruled Trump legally fired the entire U.S. African Development Foundation board, which is another independent government agency created by Congress.
In his 31 page order Maddox appears to concede Humphrey’s Executor’s "has not withstood the test of time," yet ultimately determined it "remains good law and is binding on this Court."
Maddox even mentions the Supreme Court in a footnote, but maintains his order passes legal muster.
"This finding was supported by the emergency Order recently entered by the Supreme Court in Trump v. Wilcox, 145 S. Ct. 1415 (2025), where the Court determined that a stay of preliminary injunctive relief in that case was “appropriate to avoid the disruptive effect of the repeated removal and reinstatement of officers during the pendency of this litigation.” Disruption might have resulted in the instant case if Plaintiffs had been reinstated while this case was in its preliminary posture, only to have the Court later deny relief in its final judgment and subject Plaintiffs to removal again. The risk of such disruption is no longer a factor now that the Court is granting permanent injunctive relief as a final judgment."
Eric Wessan, the current Solicitor General for the State of Iowa reacted on X stating, "Judicial resistance to the Supreme Court's recent orders is a novel development. I hope the Chief Justice's Normal Appellate Process is able to review and deal with this quickly! Perhaps the Supreme Court needs to offer more guidance--else each lawful removal will be stymied."
Harvard Law Professor Adrian Vermeule also chimed in posting, "Another day, another district judge so far over the line that the line isn’t visible in the rear-view mirror. One way or another, this has to end."
Maddox's ruling is the latest judicial setback for the Trump White House.
Compared to his predecessors, Trump has been on the receiving end of an overwhelming tidal-wave of nationwide injunctions.
The once little-used judicial remedy has become somewhat of the norm during Trump's Presidency.
Judges in Maryland, and a few other Northeast states, are among the most frequent to issue injunctions.
Some have already been overturned on appeal, including lawsuits over DEI grants and mass layoffs at government agencies.
Trump and his allies have heavily criticized unelected district level judges for hampering his agenda, sparking separation of powers concerns.
Some critics have supported the idea of Trump ignoring the courts, considering they have no true enforcement mechanism against a sitting President with sweeping immunity and control of the DOJ tasked with carrying out their orders.
His lawyers argue the constitution limits district judges to narrow rulings, only within their districts, for the specific plaintiffs seeking relief.
The U.S. Supreme Court is currently considering the Trump Administration's arguments against injunctions.