Opinion of the Court
as “neglect of duty” or “malfeasance.” 5 U. S. C. §§7521(a), 1202(d). An ALJ assigned to hear an SEC or FTC enforcement action has authority, much like a regular trial judge, to resolve motions, hold a hearing, and then issue a decision. See 16 CFR §§3.21–3.56 (2021); 17 CFR §§201.221–201.360 (2021).
A losing party may appeal the ALJ’s ruling to the Commission; alternatively, the Commission may undertake review on its own initiative. See 16 CFR §§3.52–3.53; 17 CFR §§201.410–201.411. Upon completion of internal review, the Commission enters a final decision. See 16 CFR §3.54; 17 CFR §201.411(a). Or if no such review has occurred, the ALJ’s ruling itself becomes the decision of the Commission. See 15 U. S. C. §78d–1(c); 16 CFR §3.51(a).
The Exchange Act and FTC Act both provide for review of a final Commission decision in a court of appeals, rather than a district court. Under the Exchange Act, “[a] person aggrieved by [an SEC] final order … may obtain review of the order” by filing a petition in a court of appeals. 15 U. S. C. §78y(a)(1). That petition gives the appellate court “jurisdiction” to “affirm or modify and enforce or to set aside the order in whole or in part.” §78y(a)(3). The FTC Act similarly provides that the party subject to an FTC order may “obtain a review of such order” in a court of appeals, and grants the court “jurisdiction” to “affirm[], modify[], or set[] aside the order.” §45(c).
The cases before us, though, did not take the above-described course. In each, the respondent in an administrative enforcement action sued in district court prior to an ALJ decision, seeking to enjoin the Commission’s proceeding. Each suit charged that some fundamental aspect of the Commission’s structure violates the Constitution; that the violation made the entire proceeding unlawful; and that being subjected to such an illegitimate proceeding causes legal injury (independent of any rulings the ALJ might make). Finally, each suit premised jurisdiction on district
