LeBlanc v. United States Privacy and Civil Liberties Oversight Board

The district court applied Humphrey's Executor to hold that the PCLOB's multi-member structure and quasi-judicial review function over national security surveillance programs constitute grounds for congressional for-cause removal protection, finding President Trump's at-will removal of LeBlanc violated that statutory safeguard. On appeal, the D.C. Circuit must evaluate whether this protection survives the Supreme Court's narrowing trajectory in Seila Law and Collins v. Yellen, which constrained removability restrictions outside the traditional independent-commission model. The court will likely examine whether the PCLOB's dual mandate institutional independence coupled with oversight of executive surveillance falls within the Humphrey's Executor carve-out for quasi-legislative and quasi-judicial bodies, or whether its connection to national security enforcement pulls it into the category of removable executive positions. The resolution hinges on how expansively the court reads the 'sensitive national security role' exception and whether it sees the PCLOB's independence as essential to its reviewing function or as an unconstitutional constraint on presidential power.