Federal Maritime Commission v. Port of Seattle

This case presents a question we had thought settled by the Supreme Court thirty-five years ago, namely, whether a district court has jurisdiction to deny the enforcement of a subpoena issued by an administrative agency on the ground that the agency lacked jurisdiction over the subject matter of the inquiry. Since the Supreme Court has held that a district court’s function in enforcing an administrative subpoena extends no further than to ascertain whether the information sought is “not plainly incompetent or irrelevant to any lawful purpose” of the administrative authority (Endicott Johnson Corp. v. Perkins, 317 U.S. 501, 509 , 63 S.Ct. 339, 343 , 87 L.Ed. 424 (1943)), we reverse the ruling of the district court.

The Federal Maritime Commission (the “Commission”) appeals from an order of the United States District Court for the Western District of Washington denying the Commission’s application for the enforcement of certain discovery orders of its Administrative Law Judge against the Port of Seattle (the “Port”) on the grounds, first, that the district court was under a duty to enforce the Commission’s discovery orders without requiring a showing of statutory coverage…