Collins v. Yellen

Applying Seila Law to the FHFA's single-director structure, the Court found the removal restriction unconstitutional, but then applied a causation filter to determine relief. Shareholders had to demonstrate that a constitutionally supervised FHFA director would not have adopted the Third Amendment sweeping their profits. Because the shareholders could not overcome this burden (they could not show the structural defect actually caused the Net Worth Sweep rather than the agency's independent judgment during conservatorship), the constitutional violation did not entitle them to monetary recovery. The decision thus carved out a middle path: invalidate the unconstitutional structure going forward while insulating past agency decisions from being unwound based solely on the constitutional defect.