A federal judge in North Carolina dismissed Joe Manis’ lawsuit challenging the USDA’s administrative process used to charge him with entering a “sore” horse in a competition, upholding the constitutionality of the agency’s adjudication under the Horse Protection Act (HPA). Manis argued that the administrative law judge (ALJ) process violated several constitutional provisions, including the Appointments Clause, removal protections for ALJs, the right to a jury trial, and Article III court adjudication. However, US District Judge William Osteen ruled that the USDA’s process complies with constitutional requirements, finding the ALJs to be properly supervised inferior officers and that the HPA falls under the “public rights” exception allowing agency adjudication without violating Article III or the Seventh Amendment.

The decision followed a unanimous ruling by the 4th US Circuit Court of Appeals, which denied Manis’ request for an injunction, concluding he failed to show irreparable harm without preliminary relief. The appellate court rejected Manis’ reliance on the 2023 Axon Enterprise case, clarifying that the mere existence of an allegedly unconstitutional agency proceeding does not automatically justify halting the process. The USDA’s administrative complaint stemmed from allegations that Manis entered a horse made “sore” through abusive practices to mimic a desired gait, violating the HPA’s prohibition on exhibiting sore horses in competitions. Manis faced a $10 penalty and a one-year ban from horse-related events following the administrative ruling.