On December 3, 2024, in Texas Top Cop Shop, Inc. v. Garland, Judge Mazzant of the U.S. District Court for the Eastern District of Texas, “determined that the CTA and Reporting Rule are likely unconstitutional for purposes of a preliminary injunction.” Based on that determination, the Court issued a nationwide preliminary injunction prohibiting the enforcement of the CTA and stayed the filing deadlines (including the upcoming deadline for certain entities to report prior to January 1, 2025) pending further order of the Court.
The Court also stated that it, “has not made an affirmative finding that the CTA and Reporting Rule are contrary to law or that they amount to a violation of the Constitution.”
As of the writing of this alert, the Department of Justice has not yet indicated whether it intends to appeal the Court’s ruling and seek a stay of the injunction.
Given the preliminary nature of the injunction and the possibility of the DOJ pursuing an appeal and requesting a stay of the injunction, entities with reporting obligations under the CTA should be on alert for further developments that could impact the Court’s injunction.
