ICCR’s legal work in support of shareholders’ rights (includes litigation and amicus briefs):
Key Legal Filings:
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- On 03/19/26 the Congregation des Soeurs des Saints Noms de Jesus et de Marie (Mission Funds) sued UnitedHealth Group for declaring its intent unilaterally to exclude Mission Funds’ shareholder proposal from the company’s proxy statement. The resolution addresses the health and consumer impacts, as well as other consequences, of UHG’s aggressive acquisition and vertical integration strategies. The court declined to issue a preliminary injunction, but did not dismiss the case as requested by the company. After considering alternatives, and given that UHG has already filed its definitive proxy statement in anticipation of its June 1, 2026, annual meeting, Mission Funds decided to withdraw the case, asking that the company commit to dialogue.
- On 03.16.26, ICCR joined an amicus (i.e., “friend of the court”) brief in support of Anthropic’s case suing the U.S. Department of War for sanctioning the company as a “supply chain risk” in retaliation for Anthropic’s refusal to enter into contracts with the War Dept. without guardrails against the use of their AI technology in domestic surveillance and autonomous weapons. Anthropic sued in 2 separate courts. On March 26, 2026, the U.S. District Court for the Northern District of California granted Anthropic’s request for a preliminary injunction, blocking the government from enforcing its supply chain risk designation of Anthropic. But on April 8th in the D.C. Circuit Court of Appeals, the court refused to grant the preliminary injunction. In the D.C. Circuit, the case now continues, and ICCR has joined in yet another amicus brief, filed on April 22, 2026, in support of Anthropic.
- SEC Lawsuit. On 03/19/26, ICCR and As You Sow filed a lawsuit in federal court against the SEC, alleging that the SEC’s November announcement that it was withdrawing from the No Action process for shareholder proposals is a violation of the federal Administrative Procedure Act. We are represented by Democracy Forward in this matter. See our press release. See a copy of the complaint on the Harvard Law School Forum on Corporate Governance.
- Nathan Cummings Foundation Files Suit to Prevent AXON from Excluding its Shareholder Proposal on Political Spending Transparency 02/18/26. AXON had notified the Securities and Exchange Commission (SEC) of its intent to exclude the proposal, asserting that the request for political spending disclosure constitutes “micromanagement”. AXON settled with NCF on 03/11/26 and agreed to detailed political spending disclosure and transparency.
- Motion for Summary Judgement Regarding SB 2337 1/7/26. ICCR filed a Motion for Summary Judgment in its challenge against Texas statute SB 2337. ICCR’s suit, filed in federal court in November 2025 and joined by United Church Funds and Ceres, focused on a newly-adopted law that imposes unprecedented and burdensome unconstitutional obligations on ICCR and similarly-situated organizations.
- Amicus Brief: Slaughter v. Trump 11/13/25. ICCR joined this amicus brief challenging the Administration’s attempted firing of FTC Commissioner Rebecca Kelly Slaughter
- Lawsuit to Block Wide Enforcement of Texas Law That Restricts Shareholder Advocacy, Free Speech 11/10/25. ICCR joined a lawsuit to block wide enforcement of the new Texas law, SB 2337, that would prevent investors from having unrestricted access to expert advice about their investments.
- Amicus Brief in Support of Private Employers with Diversity, Equity and Inclusion Programs, and Organizations that Support Them 9/24/25. ICCR signed onto this amicus brief in support of diversity, equity, inclusion and accessibility programs for business.
- Amicus Brief in Support of National Association of Diversity Officers in Higher Education 5/15/25. ICCR filed this amicus brief in support of diversity, equity, inclusion and accessibility principles for business.
- Amicus Brief in Support of the FTC’s Rule Banning Non-Compete Agreements 1/9/25. ICCR filed this amicus brief in the 5th circuit making the investor case in support of the FTC’s rule banning non-compete agreements.
- Amicus Brief in Support of the FTC’s Rule Banning Non-Compete Agreements 11/12/24. ICCR filed this amicus brief in the United States Court of Appeals for the 11th Circuit supporting the FTC against a challenge to the FTC’s rule banning non-compete agreements.
- Amicus Brief in Support of Nasdaq Diversity Rule 4/29/24. ICCR filed this amicus brief in support of the Nasdaq Diversity Rule that will provide a standardized disclosure tool for investors.
- Amicus Curiae Brief Submitted by ICCR in Support of the SEC in SEC v NCPPR Case 9/20/23. ICCR submitted this amicus curiae brief in support of the SEC in the case SEC vs NCPPR
- Reply in Support of a Motion for Summary Judgement 12/17/21. ICCR, As You Sow and Jim McRitchie filed this reply in support of their September motion for summary judgement.
- Motion for Summary Judgement 09/20/21. ICCR joined with plaintiffs in filing this motion for summary judgement in the 6/14/21 case.
- Lawsuit Seeking to Overturn Trump-Era SEC Rule Revision 6/14/21. ICCR, As You Sow and James McRitchie filed this lawsuit to overturn the SEC’s revisions to rule 14a-8
ICCR’s policy work in support of shareholders’ rights (includes public statements and letters):
Key Public Statements/Comment Letters:
- ICCR Comment Letter on Reg S-K, Opposing the Weakening of Corporate Disclosures 04/16/26. SEC-mandated disclosures are a vital source of information about issuers’ businesses, risks, and governance. Investors use to information from these disclosures to make security buy/sell decisions and to inform stewardship actions. The SEC’s leadership is planning a rule-making on Reg S-K which governs non-financial disclosures in SEC filings, likely seeking to significantly weaken existing corporate disclosure requirements. ICCR issued this letter in response.
- ICCR Statement in Response to the Overturning of the Endangerment Finding 02/13/26. ICCR released this statement after the Environmental Protection Agency officially rescinded the Endangerment Finding, which has underpinned the ability of the federal government to regulate greenhouse gas emissions from power plants, vehicles, and other heavy emitters.
- ICCR Statement on Immigration 02/03/26. ICCR released this statement in response to the anti-immigrant policies of the U.S. administration, the killing of civilians by federal agents and the increasing rollback of constitutional rights.
- ICCR Statement on SEC Decision to Bar Filing of Exempt Solicitations for all but the Largest Shareholders 01/28/26. ICCR released this statement following the SEC’s move to prevent the vast majority of shareholders from filing their Notices of Exempt Solicitation on the EDGAR platform, a vehicle via which shareholders have been able to communicate with other shareholders regarding recommendations either in support of or against resolutions put forth for a vote in a company’s proxy statement.
- In Defense of Shareholder Rights: Navigating the Current Policy Landscape 01/22/26. ICCR released this statement after the SECʼs Division of Corporation Finance announced that its staff will not during the 2026 proxy season respond to corporate no-action requests.
- ICCR Responds to Executive Order on Proxy Advisors and Shareholder Proposals 12/12/25. ICCR released this statement following an Executive Order directing federal agencies to consider actions targeting proxy advisory firms, shareholder proposals, and ESG investing more broadly.
- ICCR Letter to SEC Chair Paul Atkins 11/05/26. ICCR and four other investor organizations, including the AFL-CIO, Ceres, Interfaith Center on Corporate Responsibility (ICCR), Shareholder Rights Group, and US SIF submitted a letter to SEC Chair Paul Atkins expressing serious concerns about his keynote speech at an October forum in Delaware. The speech triggered serious investor concerns regarding the Chairman’s approach toward the SEC’s shareholder proposal rule.
- Request for Reconsideration and Rescission of No-Action Letter re: Exxon Mobil Corporation’s Retail Voting Program 09/20/25. As You Sow and ICCR filed a request with the U.S. Securities and Exchange Commission (SEC) to rescind its effective approval of ExxonMobil’s “Retail Voting Program.” Exxon’s program, under the guise of ‘assisting’ retail voters, seeks to opt retail shareholders into a program that would cast their votes in favor of management for all future meetings, unless and until shareholders take steps to opt-out.
- ICCR Releases Faith-Consistent Investing Statement 08/26/25. ICCR issued this statement in defense of the practice of faith-consistent and sustainable investing as a question of religious freedom protected under the U.S. Constitution.
- Investor Statement on the Economic and Social Importance of a Robust Public Health System, 04/17/25. ICCR issued this statement affirming affordable and equitable healthcare as a human right and recognize a robust public health system as essential to the well-being of our citizens, our workforce, and a thriving economy.
- ICCR, Shareholder Rights Group, As You Sow Letter to SEC Staff on Legal Bulletin 14M, 02/18/25. The groups sent a letter to the Securities and Exchange Commission requesting that the Staff refrain from applying the guidance provided in Staff Legal Bulletin 14M to any shareholder proposals filed with companies prior to the issuance of the bulletin.
- Investor Statement Calling for Comprehensive and Just Immigration Reform, 02/19/25. ICCR’s letter called on Congress to reject piecemeal immigration-related orders and directives that only prolong uncertainty and create confusion and instead come together to enact comprehensive immigration reform that protects all stakeholders and fosters long-term economic growth.
- ICCR Letter to the Business Roundtable Board Members. On August 22, 2024, ICCR sent this letter to board members of the BRT, calling out conflicts arising from an amicus brief it filed opposing the SEC’s Climate Disclosure Rule.
- ICCR Statement in Response to ExxonMobil Lawsuit to Block Shareholder Climate-Related Proposal. On January 21, ExxonMobil ($XOM) filed suit in Texas against two shareholders in an attempt to block a shareholder proposal urging the company to accelerate the reduction of greenhouse gas (GHG) emissions and to disclose new plans and timetables for these reductions. ICCR released this statement on 01/24/24.
- Comment Letter from Investors Supporting 14a-8 Rule Amendments, 10/31/23. An ICCR letter signed by investors, fiduciaries, and organizations in support of the pending rulemaking entitled Substantial Implementation, Duplication, and Resubmission of Shareholder Proposals Under Exchange Act Rule 14a-8.
- Letter to CEO Members of the BRT Regarding their Political Spending Activities, August 10, 2023. Members of the Interfaith Center on Corporate Responsibility (ICCR) announced they had sent letters to members of the Business Roundtable urging them to align political spending with their stated core values, to mitigate both reputational risks to the company, and broader risks to democracy.
- ICCR Comment Letter to ISSB on Systemic Risk and Impact Materiality, 8/30/23. In this letter, we provide some general comments with respect to the ISSB’s agenda for its next two year work plan as well as our views on specific priority areas for the ISSB’s attention. In brief, we urge the ISSB to embrace disclosure not only of sustainability information material to an entity’s financial prospects, but also of material impacts affecting stakeholders, the economy, the natural environment, and systems on which ICCR members depend to generate returns.
- Investor Letter t the U.S. Chamber of Commerce to Advocate for Public Policy to Reduce GHG Emissions, 07.28.22. ICCR led a group of investors representing U.S. $131B in assets under management in sending a letter to the Directors of the U.S. Chamber of Commerce (U.S. Chamber) calling on them to advocate for the public policies needed to bring greenhouse gas emissions (GHG) emissions in line with Paris goals.
- ICCR Comment Letter on Mandatory SEC Climate Change Disclosures, 6.14.21. In response to a request for public comment, ICCR submitted the following letter to the SEC making the case for the need for mandatory climate disclosure to help investors meet their fiduciary obligations.
- ICCR Letter to More than 200 Corporations Regarding Free and Fair Elections in 2020, 10.22.20. ICCR sent a letter to more than 200 corporations — including many members of the Business Round Table — calling on them to help ensure free and fair elections, by endorsing 6 key principles.
- ICCR Statement on the US Withdrawal from the WHO, 10.14.20. On July 7, 2020, the White House communicated to the UN Secretary General that the United States would officially withdraw from the World Health Organization (WHO). ICCR issued this statement in response.