Date Filed: December 3, 2025
Original Court: U.S. District Court for the Northern District of Texas
Case Status: Pending
While workplace safety is unquestionably important, Congress gave OSHA an extraordinarily broad mandate: the power to issue any rules it considers “reasonably necessary or appropriate” for workplace safety. For decades, OSHA has relied on that open-ended language to regulate nearly every corner of the American economy—from office settings to retail shops to small family businesses—without meaningful limits from Congress.
CAF along with the Southeastern Legal Foundation (SLF) represent two Texas-based agricultural trade organizations whose members work across the fresh fruit and vegetable supply chain, including many small and family-owned businesses. Both trade organizations and their members—along with virtually every other employer in America—must comply with costly, complex, and ever-expanding OSHA rules, even though Congress never made the fundamental policy judgments those rules require. The Constitution vests legislative power in Congress alone. If Congress wants OSHA to regulate every workplace in America, it must make those basic policy choices itself—not hand the agency a blank check to decide how much safety is “enough,” what risks justify billions in compliance costs, or which businesses must shoulder those burdens.
CAF and SLF argue that OSHA’s general rulemaking provision violates the nondelegation doctrine because it places no real limits on the agency’s power. The lawsuit asks the court to reaffirm that Congress cannot outsource its lawmaking responsibilities and to halt OSHA’s enforcement of standards issued under this unconstitutional delegation.
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