Last week, an Eleventh Circuit panel unanimously upheld a federal district court’s summary judgment ruling in favor of the Federal Trade Commission (FTC) concerning advertising and disclosure practices related to a national fuel card program. The decision affirms the FTC’s authority to seek and obtain broad injunctive relief for unfair or deceptive acts and practices, particularly where fee disclosures and consent mechanisms are found to be inadequate.

In its opinion, the three-judge panel rejected a number of arguments challenging the scope of the district court’s relief and confirmed that forward-looking injunctive measures were appropriate given the record before it. The panel affirmed summary judgment on all five counts of the FTC’s complaint against the company and on four of five counts asserted against its chief executive officer.

The ruling may bring to a close more than seven years of litigation, spanning multiple changes in FTC leadership and enforcement priorities, as well as the Supreme Court’s decision in AMG Capital Management, LLC v. FTC, which narrowed the agency’s ability to obtain monetary relief under Section 13(b) of the FTC Act.