Ticor Title Insurance Co. v. FTC

814 F.2d 731 (D.C. Cir. 1987)

Facts

Ps brought a facial constitutional challenge under the general federal question statute, 28 U.S.C. Sec. 1331 (1982), to the authority of D to initiate and prosecute a complaint against them. Ps also have nonconstitutional (or statutory) defenses to the D complaint, which they are currently asserting before an ALJ in an ongoing administrative proceeding.