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William A. Goddard, et al. v. United States

Paid petition · United States Court of Appeals for the Ninth Circuit, No. 24-5449 · judgment June 11, 2025


Certiorari denied · November 10, 2025
Pre-decision estimate: 3% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

  1. Whether a law firm can be denied the opportunity to challenge an IRS summons for law firm trust account records based solely on an IRS declaration which states only in general terms that the summons would aid IRS in the collection of taxes owed by a law firm employee.

  2. Whether an allegation of bad faith actions by an IRS employee that were approved by an IRS manager is sufficient to show bad faith by the agency thereby requiring an evidentiary hearing.

Counsel of record

For petitioner
Bradley A. Patterson
LGI LLP

For respondent
D. John Sauer
Solicitor General

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Nov 10 2025
    Petition DENIED.
  2. Oct 08 2025
    DISTRIBUTED for Conference of 11/7/2025.
  3. Oct 06 2025
    Waiver of right of respondent United States to respond filed.
  4. Sep 09 2025
    Petition for a writ of certiorari filed. (Response due October 16, 2025)