Plaintiff alleges federal agency’s unconstitutional procedures following workplace safety citation

R&L Carriers Shared Services, LLC is challenging the constitutionality of a federal agency’s procedures in a legal battle that could have significant implications for administrative law. On January 29, 2026, R&L Carriers filed a complaint in the United States District Court for the Southern District of Ohio against the Occupational Safety & Health Review Commission (OSHRC), the United States Department of Labor (DOL), and key officials Jonathan Snare and Lori Chavez-DeRemer.

The case arises from an October 15, 2025 citation issued by OSHA to R&L Carriers alleging three serious violations of the Occupational Safety and Health Act of 1970, with proposed penalties totaling $49,650. R&L contested these allegations on October 27, 2025. The company argues that OSHRC’s review process violates constitutional principles such as due process and separation of powers. Specifically, R&L contends that OSHRC’s appointment scheme for administrative law judges breaches the Appointments Clause of Article II of the U.S. Constitution and that their removal protections infringe upon executive power as outlined in Article II.

Furthermore, R&L asserts that because OSHRC currently lacks a quorum—only one commissioner is active—any actions it takes are invalid, denying them meaningful judicial review. The company also claims that they are entitled to a jury trial under the Seventh Amendment since the alleged violations resemble common law tort claims rather than new statutory rights.

R&L seeks declaratory judgments affirming their right to a jury trial and declaring OSHRC’s structure unconstitutional. They also request injunctive relief to halt ongoing administrative proceedings related to the contested citation. The company argues that without such relief, they will suffer irreparable harm from an unconstitutional process.

Representing R&L Carriers is attorney Steven A. Boggins from Ogletree Deakins Nash Smoak & Stewart P.C., while no specific attorneys are named for the defendants in this filing. The case is being heard by Judge Walter H. Rice under Case ID 3:26-cv-00024-WHR-PBS.