Federal Register Vol. 91, Issue 55

The Government Publishing Office has published Volume 91, Issue 55 of the Federal Register on March 23, 2026. This issue contains various government notices and announcements. It serves as an official record of federal agency activities.

Bankruptcy Judge's Special Master Appointment Violates Article III

The DOJ Office of Legal Counsel issued an opinion stating that allowing bankruptcy judges to unilaterally appoint special masters for constitutionally non-core claims would violate Article III of the Constitution. This opinion addresses proposals to amend the Federal Rules of Bankruptcy Procedure.

North Northamptonshire Council Education Support Services Framework

North Northamptonshire Council has issued an updated notice for a Framework Agreement for Educational Support Services valued at £31.2M. The framework will initially comprise five lots: Educational Psychology, Speech and Language Therapy, Occupational and Sensory Therapy, Tuition, and Alternative Provision, supporting children and young people aged 0-25.

Federal Student Aid Training Conference 2026 Session Recordings Available

The U.S. Department of Education's Federal Student Aid (FSA) has announced that session recordings from the 2026 Federal Student Aid Training Conference are now available online. Partners can access the recordings and presentation materials on the FSA YouTube channel and the FSA Training Conference website.

ED Enforcement Priorities for Audited Financial Statements

The U.S. Department of Education (ED) announced delayed enforcement priorities for certain audited financial statement requirements under § 668.23(d)(1). Enforcement for fiscal-year alignment with IRS returns, ED-requested fiscal years, expanded financial statement applicability, and disclosure of no related-party transactions will not be a priority until at least July 1, 2027.

CDPH Warns of Illness Linked to Raw Cheddar Cheese

The California Department of Public Health (CDPH) is warning consumers and businesses not to eat, serve, or sell raw cheddar cheese manufactured by RAW FARM, LLC due to an outbreak of Shiga toxin-producing E. coli (STEC) O157. Seven cases have been reported across multiple states, with two hospitalizations, including two children under five.

DOJ Proposed Modification to Consent Decree under CERCLA

The Department of Justice has published a notice regarding the proposed modification of a consent decree under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). This notice indicates a public comment period may be forthcoming or has recently closed, allowing for input on the proposed changes to the decree.

State Department Statement on Namibia National Day

The U.S. Department of State issued a statement congratulating Namibia on its 36th Independence Day. The statement reaffirmed the strong partnership between the United States and Namibia, highlighting collaboration on health, economic development, and emerging opportunities.

OFAC Iran-Related General License U for Crude Oil Sales

OFAC has issued Iran-related General License U, authorizing the delivery and sale of crude oil and petroleum products of Iranian-origin loaded on vessels as of March 20, 2026. This license provides specific exceptions to sanctions for certain oil-related transactions.

Presidential Message on Nowruz

The White House issued a presidential message celebrating Nowruz, the Persian New Year and the arrival of spring. The message extends best wishes to Americans celebrating the holiday and expresses hopes for peace and human dignity.

Congressional Bill S. 4138 Signed into Law

The President signed into law Congressional Bill S. 4138, which waives the 60-day notice requirement for the posthumous honorary promotion of Captain Cody Khork of the United States Army. This action modifies existing procedural requirements for military promotions.

Marhaux Judgment on Freedom of Movement and Income Tax

The Court of Justice of the European Union ruled in the Marhaux case concerning freedom of movement for workers and income tax. The judgment addresses how earned income received in another Member State is treated for tax purposes, specifically regarding the application of bilateral tax treaties and the potential loss of tax benefits.

Aptiv Services Hungary VAT Intra-Community Goods Judgment

The Court of Justice of the European Union issued a judgment concerning Aptiv Services Hungary regarding the VAT treatment of intra-community acquisitions of goods. The case addresses the refusal of VAT deduction due to late submission of required invoices and the application of national rectification procedures.

Jason Brawley Insurance License Revoked for Fraud

The Michigan Department of Insurance and Financial Services (DIFS) has revoked Jason Brawley's insurance license due to fraud and misrepresentation. The order accepts a stipulation agreement, revoking the license immediately and prohibiting any future license applications.

Anastasiya Volchanina's Insurance License Revoked for Fraud

The Michigan Department of Insurance and Financial Services (DIFS) has revoked Anastasiya Volchanina's insurance license. The revocation is due to fraud and misrepresentation in obtaining the license and untrustworthy business practices, as admitted by the respondent in a stipulation accepted by the Director.

Andrew George License Revoked for Fraud and Exam Cheating

The Michigan Department of Insurance and Financial Services (DIFS) has revoked Andrew George's insurance license. The revocation is due to fraud and dishonest practices in obtaining the license and conducting business, as admitted by the respondent in a stipulation accepted by the Director.

Brandon Karim Insurance License Revoked for Fraud

The Michigan Department of Insurance and Financial Services (DIFS) has revoked Brandon Karim's insurance license. The revocation is due to fraud and untrustworthy conduct in business dealings, as admitted by the respondent in a stipulation accepted by the Director. Karim is prohibited from reapplying for any DIFS-administered license.

US-Japan Trade Deal Announces New Energy Projects

The U.S. Department of Commerce announced new energy projects stemming from a U.S.-Japan trade deal. These initiatives aim to foster collaboration and investment in clean energy technologies between the two nations.

Meaker v. State of Florida - Criminal Appeal

The Florida District Court of Appeal affirmed the lower court's decision in Meaker v. State of Florida. The appeal was filed under docket number 1D2025-0947. The court's disposition was an affirmation, indicating no changes to the original ruling.

Charles Ruffenach v. Deutsche Bank National Trust Company - Attorneys' Fees Award

The Florida District Court of Appeal reversed an award of attorneys' fees in the case of Charles Ruffenach v. Deutsche Bank National Trust Company. The court found that prior appellate decisions incorrectly imposed requirements for evidentiary hearings and expert testimony for attorneys' fees awards, which are not mandated by statute or rule.

Wise v. State of Florida - Criminal Appeal

The Florida District Court of Appeal affirmed the lower court's decision in the case of Wise v. State of Florida. The appeal was filed by Brian Thomas Wise, and the court's disposition was 'Affirmed'.

Stacy v. State of Florida - Criminal Appeal

The District Court of Appeal of Florida affirmed the lower court's decision in Stacy v. State of Florida. The appeal, identified by docket number 1D2024-2751, was reviewed and the disposition was affirmed on March 20, 2026.

Diversified Land Management, LLC v. Luis A. Agosto and Melissa Alicea - Landlord Negligence

The Florida District Court of Appeal reversed a trial court's denial of a directed verdict for Diversified Land Management, LLC. The court found that the plaintiff failed to present sufficient evidence that the absence of smoke detectors was a proximate cause of his injuries from a cooking oil fire. The case was remanded for entry of a directed verdict for the landlord.

Tasman v. Jusakos - Florida District Court of Appeal Opinion

The Florida District Court of Appeal affirmed a lower tribunal's decision in the case of Tasman v. Jusakos. The opinion references a legal standard for individual actions versus derivative ones in corporate matters, citing prior case law. The case involves a dispute between two sets of individuals.

Florida DCA Denies Certiorari, Flags AI-Generated Filings

The District Court of Appeal of Florida denied a petition for writ of certiorari, citing concerns with AI-generated filings. The court noted that the petition contained numerous citations to non-existent cases and inaccurate legal propositions, highlighting a growing issue with AI-assisted legal submissions.

Marchant v. State of Florida - Criminal Appeal

The Florida District Court of Appeal affirmed the lower court's decision in Marchant v. State of Florida. The appellate court issued a per curiam opinion affirming the disposition without further comment. The case involves an appeal from the Circuit Court for Bradford County.

Turner v. State of Florida - Criminal Appeal

The Florida District Court of Appeal affirmed the lower court's decision in Turner v. State of Florida. The appellate court issued a per curiam opinion, affirming the disposition without further detail in the provided text.

Bburgett LLC v Benfam Holdings LLC - Reversed Foreclosure Judgment

The Florida District Court of Appeal reversed a foreclosure judgment granted by the lower court in Bburgett LLC v. Benfam Holdings LLC. The appellate court found that the trial court failed to state its reasons for granting summary judgment as required by Florida Rule of Civil Procedure 1.510(a). The case is remanded for the trial court to enter a compliant order.

Swails v. State of Florida - Criminal Appeal

The Florida District Court of Appeal affirmed the lower court's decision in Swails v. State of Florida. The case involves an appeal from the Circuit Court for Escambia County. The disposition of the case was 'Affirmed'.

Wal-Mart Stores East, LP v. Dorothy Wynn - Negligence Appeal

The Florida District Court of Appeal affirmed a final judgment against Wal-Mart Stores East, L.P. in a negligence case brought by Dorothy Wynn. The court found no error in the trial court's exclusion of Wal-Mart's expert witness testimony and certified the decision as potentially conflicting with prior rulings.

Stacy v. State - Criminal Appeal

The Florida District Court of Appeal issued an opinion in Stacy v. State of Florida. The court affirmed the lower court's decision, with no known citations or specific regulatory impact beyond the immediate case.

Rios v. State of Florida - Criminal Appeal Disposition

The Florida District Court of Appeal affirmed the lower court's decision in Rios v. State of Florida. The case, consolidated under docket numbers 1D2024-3056 and 1D2024-3058, involved a criminal appeal. The court's disposition was 'Affirmed'.

Crafted Audio, LLC v. Clair Global Integration, LLC - Summary Judgment Appeal

The Florida District Court of Appeal affirmed a lower court's summary judgment decision in the case of Crafted Audio, LLC v. Clair Global Integration, LLC. The court cited Florida Rule of Civil Procedure 1.510(a) regarding summary judgment standards. The appeal was filed under docket number 6D2025-0534.

Voyager Digital Consent Order - Texas Securities Board

The Texas State Securities Board (TSSB) has issued a consent order against Voyager Digital Ltd., Voyager Digital Holdings, Inc., and Voyager Digital, LLC. The order addresses violations related to the offering and selling of unregistered securities, unregistered dealers and agents, and materially misleading statements concerning their cryptocurrency brokerage services and the Voyager Earn Program.

Delaware DUI Checkpoint and Sober Rides Program Results

The Delaware Office of Highway Safety reported the results of its St. Patrick's Day weekend DUI checkpoint and Sober Rides Program. The initiative led to 23 DUI arrests and two fatalities over the holiday weekend, with 1,144 individuals utilizing the Sober Rides program.

Potassium Iodide Distribution in Middletown

The Delaware Division of Public Health (DPH) announced a potassium iodide distribution event scheduled for April 2 in Middletown. This distribution is in preparation for potential emergencies at the nearby Salem Hope Creek Nuclear Generating Station.

DSHA Launches Healthy Heart Program for Public Housing Residents

The Delaware State Housing Authority (DSHA) has launched a new Healthy Heart Program aimed at improving the cardiovascular health of residents in public housing. This initiative was announced on March 20, 2026, and focuses on community health and wellness.

DEA Phoenix Operation Mechanic Results Highlighted

The DEA Phoenix Field Division, in partnership with law enforcement agencies, announced the results of Operation Mechanic. This operation focused on combating fentanyl trafficking and related criminal activities, contributing to a broader national effort to reduce drug-related harm.

DEA Seizes 30,000 Fentanyl Pills and 15 Kgs Powder

The DEA announced the seizure of 30,000 fentanyl pills and 15 kilograms of fentanyl powder as part of Operation FentanylFreeAmerica Phase 2. A trafficker linked to the Sinaloa cartel was arrested during the operation, which involved collaboration with local law enforcement agencies.

SAM.gov Environmental Compliance Services Contract Opportunity

The General Services Administration (GSA) has posted a new contract opportunity notice on SAM.gov for Environmental Compliance Services related to an ALP Forest Management Plan. The solicitation is set aside for small businesses and has a due date for offers on April 10, 2026.

USACE Willapa Sediment Characterization Service Contract Opportunity

The US Army Corps of Engineers has issued a solicitation for environmental consulting services to perform sediment characterization in Willapa Bay, Washington. This is a total small business set-aside contract opportunity.

Groundwater Sampling of Monitor Wells, Grand Teton Contract Opportunity

The General Services Administration (GSA) has updated a contract opportunity for groundwater sampling services in Grand Teton National Park. The opportunity is set aside for small businesses and has a NAICS code of 541620. The updated offer due date is March 24, 2026.

HUD Lead-Based Paint Evaluation Services Contract Award

The Department of Housing and Urban Development (HUD) has awarded an Indefinite Delivery Indefinite Quantity (IDIQ) contract valued at $4,000,000.00 for Lead-Based Paint Evaluation Services in Atlanta, GA. The contract was awarded to ZIMMETRY ENVIRONMENTAL MANAGEMENT, CORP under an 8(a) Set-Aside.

HUD Lead-Based Paint Evaluation Services Contract Awarded

The Department of Housing and Urban Development (HUD) has awarded an Indefinite Delivery Indefinite Quantity (IDIQ) contract valued at $4,000,000.00 for Lead-Based Paint Evaluation Services in Philadelphia. The contract was awarded to ZIMMETRY ENVIRONMENTAL MANAGEMENT, CORP under an 8(a) Set-Aside.

IRS Written Determination: Extension for Entity Classification Election

The IRS has released a written determination granting an extension of time for an entity (X) to file Form 8832, Entity Classification Election. The entity inadvertently failed to timely elect to be classified as an association taxable as a corporation for federal tax purposes.

IRS Written Determination on Qualified Opportunity Fund Election Extensions

The IRS has issued a written determination granting relief under sections 301.9100-1 and 301.9100-3 for a taxpayer's late election to self-certify as a Qualified Opportunity Fund. The determination addresses the specific facts of a limited liability company that failed to file Form 8996 due to a misunderstanding of reporting requirements.

IRS Ruling on Inadvertent S Corporation Election Termination

The IRS has issued a written determination addressing an inadvertent termination of an S corporation election due to late Qualified Subchapter S Trust (QSST) elections. The ruling grants relief under Section 1362(f), allowing the corporation to retain its S corporation status.

IRS Written Determination on S Corporation Reorganization and Equity Grants

The IRS has released a written determination (PLR-112688-25) addressing a corporate reorganization involving an S corporation and subsequent equity grants to employees. The determination clarifies the tax treatment of these transactions, particularly concerning the S corporation status and the issuance of shares under employee compensation plans.

IRS Written Determination: Extension for Entity Classification Election

The IRS has released a written determination granting an extension of time for a foreign eligible entity to file an election to be treated as a disregarded entity for U.S. federal income tax purposes. This determination addresses the application of § 301.9100-3 for late entity classification elections.

IRS Written Determination: Extension of Time for Tax Elections

The IRS has issued Written Determination 202612008, granting an extension of time for a taxpayer to make a regulatory election to adopt a specific taxable year. The determination addresses the criteria for relief under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations.