Skip to main content

Sam Callahan, former Senior Counsel of the Office of Management and Budget (OMB), focuses on appellate and complex civil litigation with an emphasis on administrative law and regulatory matters. Sam has argued federal appeals and briefed dozens of cases across federal and state courts, winning major cases involving the Administrative Procedure Act (APA), constitutional and statutory interpretation, antitrust, insurance, voting rights, and maritime law. Sam also provides strategic counsel to businesses navigating high-stakes regulatory frameworks and government investigations.

At OMB, Sam supervised major litigation, reviewed regulations, managed legal and policy clearance of executive orders, and advised senior officials across the Biden Administration on key issues of administrative law, fiscal law, government contracts, and congressional oversight. As a principal legal advisor to OMB's Office of Information and Regulatory Affairs (OIRA) and Office of Federal Procurement Policy (OFPP), Sam developed extensive experience with the APA and with federal contracting and funding laws, including the Federal Property and Administrative Services Act, Federal Acquisition Regulation, and Uniform Grants Guidance. His portfolio spanned technology, healthcare, environmental, procurement, and budgetary policies, including leading review of landmark federal AI regulations.

Sam clerked for Judge Paul V. Niemeyer of the U.S. Court of Appeals for the Fourth Circuit and Judge Christopher R. Cooper of the U.S. District Court for the District of Columbia. He graduated magna cum laude from Harvard Law School, where he was an Executive Editor of the Harvard Law Review, and received degrees in economics and trumpet performance from Indiana University. He remains active in music as a member of the Capital City Symphony and as a National Endowment for the Arts grants panelist.

Experience

  • National trade association in a APA challenge to novel emissions and fuel-consumption regulations imposed on trailers. Persuaded the D.C. Circuit to stay enforcement and vacate the agencies’ rules as exceeding their statutory authority. Truck Trailer Manufacturers Ass’n v. EPA, 17 F.4th 1198 (D.C. Cir. 2021).
  • Property developer in successful appeal to the D.C. Court of Appeals regarding an agency’s application of historic preservation law to a major redevelopment project. D.C. Preservation League v. Mayor’s Agent for Historic Preservation, 236 A.3d 373 (D.C. 2020).
  • Immigrant rights organizations at the U.S. Supreme Court in a successful APA challenge to the attempted addition of a citizenship question to 2020 Census. Department of Commerce v. New York, 139 S. Ct. 2551 (2019).
  • Leading defense contractor in securing affirmance of dismissal of employee’s False Claims Act retaliation claims stemming from national-security-related investigation and termination. United States ex rel. Johnson v. Raytheon, 93 F.4th 776 (5th Cir. 2024).
  • North Carolina voters in convincing the U.S. Supreme Court to reject the “independent state legislature” theory. Moore v. Harper, 143 S. Ct. 2065 (2023).
  • Insurer in obtaining reversal of an $18 million judgment in the Third Circuit against an affiliate of AIG arising from faulty workmanship in the fracking of natural gas wells. American Home Assurance Co. v. Superior Well Services, Inc., 75 F.4th 184 (3d Cir. 2023).
  • Public health researcher in defamation action based on statements criticizing a company’s scientific research and marketing. Successfully briefed and argued Second Circuit appeal, securing dismissal on the basis that the statements were protected opinions. Valley Electronics AG v. Polis, 2022 WL 893674 (2d Cir. Mar. 28, 2022).
  • Healthcare company in securing affirmance of dismissal of a Clayton Act suit for failure to establish antitrust standing. Ekbatani v. Community Care Health Network, LLC, 2022 WL 31793 (11th Cir. 2022).
  • Former Members of Congress and House General Counsels as amici curiae in several cases at the U.S. Supreme Court and federal appellate courts involving the separation of powers, including Trump v. Mazars USA, LLP, 591 U.S. 848 (2020).
  • North Carolina voters and organizations in successful voting rights litigation to redraw North Carolina’s state legislative maps under state law. Common Cause v. Lewis, 2019 WL 4569584 (N.C. Super. Sep. 03, 2019).
  • Individual serving life sentence in briefing and arguing successful Fourth Circuit appeal asserting ineffective assistance of trial counsel. Convinced Fourth Circuit to unanimously vacate the dismissal of a § 2255 petition and to order evidentiary hearing regarding failure to seek suppression of un-Mirandized statements. United States v. Pressley, 990 F.3d 383 (4th Cir. 2021). On remand, first-chaired evidentiary hearing, persuaded district court to vacate client’s convictions and life sentence, negotiated favorable plea agreement, and secured client’s release. 
  • Cruise lines in successfully defending dozens of lawsuits, including several putative class actions, arising from COVID-19 pandemic. Developed successful strategy for moving to strike jury demands, removing to federal courts, and enforcing federal statutes limiting liability in cases presenting novel issues under maritime law.
  • Pharmaceutical trade association in numerous cases related to drug pricing and disclosure laws. 
     

Perspectives

Incumbent Electricity Providers Targeted by New DOJ Anticompetitive Regulations Task Force
Environmental Edge: Climate Change & Regulatory Insights

Credentials

Education

  • J.D., Harvard Law School, 2016, magna cum laude
  • B.M., Trumpet Performance and B.A., Economics, Indiana University Bloomington, 2013, Phi Beta Kappa

Admissions

  • District of Columbia
  • Maryland
  • U.S. Court of Appeals for the First Circuit
  • U.S. Court of Appeals for the Third Circuit
  • U.S. Court of Appeals for the Fourth Circuit
  • U.S. Court of Appeals for the Seventh Circuit
  • U.S. Court of Appeals for the Ninth Circuit
  • U.S. Court of Appeals for the Eleventh Circuit
  • U.S. Court of Appeals for the District of Columbia Circuit
  • U.S. District Court, District of Columbia

Government & Military Service

  • Senior Counsel, Office of Management and Budget (2022-2025)

Clerkships

  • U.S. Court of Appeals for the Fourth Circuit, The Honorable Paul V. Niemeyer
  • U.S. District Court, District of Columbia, The Honorable Christopher R. Cooper

Activities

  • Leadership Advisory Council, Greater Twin Cities Youth Symphonies
  • Music Grants Panelist (2021), National Endowment for the Arts
Overview