b'FHFA Structure provisions may be severed, such as it did with the As predicted in Goodwins 2019 Review, in 2020, theDodd-Frank Acts for-cause removal provision for the Supreme Court granted certiorari in Collins v. Mnuchin,CFPB Director. Given its recent ruling in Seila LawLLC No. 19-422, to review the Fifth Circuits panel andv. CFPB, the Court may once again take a middle of en banc rulings that FHFAs structure violates thethe road approach, holding that the provisions are separation of powers. Oral argument was conductedunconstitutional but also that the unconstitutional on December 9, 2020. Following on the heels of itsprovisions can be severed. ruling in Seila Law LLC v. CFPB, No. 19-7, where the Supreme Court held that the similarly structured CFPBFederal Trade Commission Actviolated the separation of powers, the Court will nowThe Supreme Court also granted certiorari to reviewdecide whether the Fifth Circuit was correct in Collinsthe Ninth Circuits decision in AMG Capital by declaring the FHFAs structure unconstitutional. IfManagement, LLC v. Federal Trade Commission, the Court finds the FHFAs structure unconstitutional,No. 19-0508. The Court is expected to addresses the Court may also decide whether the unconstitutionalwhether Section 13(b) of the FTC Act, which authorizes Proportion of State-Federal ActionsFederal State Joint8% 5% 6% 17% 6%32% 33% 32%43%38%60% 53% 60% 45% 61%2016 2017 2018 2019 202057'