An FIA statement pointed out that the court did not reverse the body's decision, reached from its own detailed investigation, that Briatore and Symonds played a deliberate role in the incident, adding that the body was considering its options, which BBC Sport understands will include an appeal.
The vote came after Mr Boehner endured pointed criticism from both Democrats and Republicans on Tuesday for House leaders' announcement the body would hold no further votes before the new Congress was sworn in.