Samuels v. Trump
Overview
Overview
Jocelyn Samuels, a Commissioner of the U.S. Equal Employment Opportunity Commission, sued the Trump administration over President Trump's attempt to remove her as a commissioner, allegedly in violation of the Civil Rights Act of 1964
The Issue
Issue
Whether the President may remove an EEOC Commissioner without cause, or whether the Civil Rights Act of 1964 restricts presidential removal authority to dismissals based on statutory grounds.
The Rules
Rule
The Civil Rights Act of 1964 establishes the EEOC and defines the qualifications, terms, and removal procedures for its Commissioners. Federal law generally restricts presidential removal of certain independent agency officials to cases where statutory cause exists, rather than permitting at-will termination.
The Application
Analysis
Samuels alleged that Trump's attempt to remove her from her position as EEOC Commissioner violated the statutory limitations on removal authority, as the action allegedly was undertaken without legitimate cause and in violation of the procedural protections established by the Civil Rights Act.
The Conclusion
Conclusion
The case was voluntarily dismissed without prejudice on July 6, 2026, following the Supreme Court's decision in Trump v. Slaughter (dismissal minute order, entry 31 on the docket). The case is terminated.
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