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On May 16, 2025, the Texas Supreme Court issued a decision ruling that, absent specific contractual language, surface owners retain ownership of the caverns created by salt mining operations.

On May 19, 2025, Deputy Attorney General Todd Blanche issued a memorandum announcing the creation of the Department of Justice’s (DOJ) Civil Rights Fraud Initiative (the Initiative), which directs DOJ attorneys to utilize the False Claims Act (FCA), 31 U.S.C. § 3729 et seq., to combat knowing violations of civil rights law and the false certification of compliance with such laws by recipients of federal funds such as educational institutions and federal contractors.

On May 22, 2025, the House passed budget reconciliation legislation referred to as “The One, Big, Beautiful Bill” (the “Bill”).

After an intense 21-hour House Rules Committee markup, early in the morning of May 22, 2025, the House passed H.R. Con. Res. 14, 119^th Cong. (2025) (the “Reconciliation Bill”), which makes significant revisions to the Inflation Reduction Act (the “IRA”) provisions.

On March 1, 2025, the Texas Business Court (the “Business Court”) implemented new local rules aimed at enhancing the efficiency and fairness of business dispute resolutions. Key changes include new provisions involving exchanging benches, supplemental jurisdiction waivers, corporate disclosure requirements, streamlined discovery dispute procedures, the concept of a Mediation Wheel, and a new guideline for the use of artificial intelligence. These rules, unanimously approved by all ten judges, mark a significant shift in the Business Court’s operational framework.

On April 8 and 9, 2025, President Donald Trump issued five Presidential Actions (four Executive Orders and one Proclamation, collectively “Presidential Actions”) for the purposes of ensuring adequate and reliable energy generation, meeting growing energy demand, and addressing the national energy emergency declared on January 20, 2025 (EO 14156).

As we previously discussed and in alignment with the U.S. Treasury Department’s previous announcement, on March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule that dramatically narrows the reporting requirements for beneficial ownership information (“BOI”) under the Corporate Transparency Act (“CTA”).

A series of recent actions undertaken by President Biden, near the end of his term, and President Trump, in the early days of his presidency, have called into question a key issue under the Outer Continental Shelf Lands Act (“OCSLA”) — whether the President can revoke a previous President’s withdrawal of areas of the United States Outer Continental Shelf (“OCS”) from oil and gas leasing.

The opening days of the 119th U.S. Congress have been marked with congressional action under the Congressional Review Act (CRA) to potentially invalidate regulations that were issued by the Internal Revenue Service (IRS) in the final days of the Biden administration.

On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”).

On February 26, 2025, the Supreme Court and all three counsel appearing before it in Ames v. Ohio Department of Youth Services, appeared to walk away in “radical agreement” — as noted by Justice Neil Gorsuch — that a majority-group plaintiff is not required to proffer more evidence of discrimination than a non-majority-group plaintiff in order to state a prima facie claim under Title VII of the Civil Rights Act of 1964.

On February 19, 2025, the Council on Environmental Quality (“CEQ”) released a pre-publication version of an interim final rule (the “Interim Rule”) to rescind all of CEQ’s previous and current regulations implementing the National Environmental Policy Act (“NEPA”) alongside a memorandum (the “Memo”) to federal agencies providing guidance on how agencies should revise their individual NEPA regulations and how they should manage NEPA reviews in the meantime.