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NEW: Judge Issues National Injunction to Block Trump Administration’s Devastating Attempt to Halt Funding For Essential Services
Press Release
DemocracyForward
February 25, 2025
https://democracyforward.org/updates/ne ... -services/

Preliminary Injunction issued after Democracy Forward filed suit and secured a prior Temporary Restraining Order on behalf of the National Council of Nonprofits, the American Public Health Association, Main Street Alliance, and SAGE

Washington, DC — Today, the U.S. District Court for the District of Columbia granted a preliminary injunction of the OMB’s freeze on federal grant disbursements that has put essential services across the nation in jeopardy, in response to a suit filed by Democracy Forward on behalf of the National Council of Nonprofits, the American Public Health Association, Main Street Alliance, and SAGE.

The motion filed by Democracy Forward sought to continue to block the White House Office of Management and Budget from pausing disbursements from all open agency grants and loans, as revealed in a memo issued January 27, 2025.

In her decision, United States District Judge Loren L. AliKhan said, “Defendants cannot pretend that the nationwide chaos and paralysis from two weeks ago is some distant memory with no bearing on this case… Plaintiffs have marshalled significant evidence indicating that the funding freeze would be economically catastrophic—and in some circumstances, fatal— to their members.”

“The preliminary injunction is a tremendous relief for thousands of nonprofit organizations throughout the country that are struggling to continue their vital work in the midst of the chaos and confusion caused by the administration’s attempted federal funding freezes. These organizations have been left to wonder whether they’ll be reimbursed for their vital work, or if they’ll need to shut down essential programs. OMB’s reckless federal funding freeze would cause catastrophic and irreversible harm to nonprofits and the communities and people they serve. This preliminary injunction allows such nonprofits to continue with their important work of providing wildfire mitigation, disaster relief, services to survivors of domestic violence, support for our nation’s veterans, and so much more.”
said Diane Yentel, President and CEO of the National Council of Nonprofits.

“The continued disbursement of these federal agency grants, previously authorized and funded by Congress, is imperative to the health of the nation,” said Georges C. Benjamin, MD, Executive Director of the American Public Health Association. “Today’s ruling is a major victory for the public’s health and the essential health services delivered by governmental and nongovernmental agencies.”

“We’ve been with small business owners on Capitol Hill all day today and a common refrain is the extent to which these freezes not only impact small business operations but also entire communities. This decision shows that organizing and targeted legal action are some of the most impactful ways to hold the Administration accountable for errant decision making that touches Main Street,” said Richard Trent, Main Street Alliance Executive Director.

“We are very pleased with the results of the preliminary injunction hearing,” said Michael Adams, SAGE CEO. “The suspension of the proposed federal funding freeze for the duration of our lawsuit allows SAGE to continue our mission to uplift and advocate for LGBTQ+ elders across the country. While we recognize this fight is far from over, we celebrate today’s important victory for our community’s elders, older Americans in general, and people who rely on essential government-funded services all across the country.”

“The Trump administration’s OMB grant freeze memo plunged people and communities across the country into chaos and uncertainty as they waited to see if critical programs would continue –from childcare, to eldercare, to food services, to health programs, to community initiatives,” said Skye Perryman, President and CEO of Democracy Forward. “This preliminary injunction will allow our clients to continue to provide services to people across this country. We are pleased that the court issued this ruling, halting the Trump administration’s lawless attempt to harm everyday Americans in service of a political goal.”

Within hours of the OMB memo, plaintiffs filed suit and sought a Temporary Restraining Order in the U.S. District Court for the District of Columbia. In response to the case, the Court issued an administrative stay, in one of the earliest moves to halt the Trump administration’s harmful policies. On January 29, the Administration purported to rescind its memo, with White House Press Secretary Karoline Leavitt citing the litigation as the administration’s reason. On February 3, a judge granted the Plaintiffs’ motion for a temporary restraining order.

Democracy Forward is a national legal organization that advances democracy and social progress through litigation, policy, public education, and regulatory engagement. For more information, please visit http://www.democracyforward.org.

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https://www.courtlistener.com/docket/69 ... nd-budget/
https://storage.courtlistener.com/recap ... 51.0_3.pdf

51. Feb 25, 2025. MEMORANDUM OPINION regarding Plaintiffs' Motion for a Preliminary Injunction 40 . See Opinion for details. Signed by Judge Loren L. AliKhan on 2/25/2025. (lclla3)(Main Document 51 replaced on 2/25/2025)(mhp) (Entered: 02/25/2025)


UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

NATIONAL COUNCIL OF NONPROFITS, et al.,

Plaintiffs,

v.

OFFICE OF MANAGEMENT AND BUDGET, et al.,

Defendants.

Civil Action No. 25 - 239 (LLA)

MEMORANDUM OPINION

On February 3, 2025, the court issued a temporary restraining order (“TRO”) prohibiting Defendants Russell Vought1 and the Office of Management and Budget (“OMB”) (collectively, “Defendants”) from implementing, giving effect to, or reinstating under a different name OMB memorandum M-25-13 freezing all federal financial assistance under open awards. ECF No. 30, at 29-30. The court found good cause to extend the TRO under Rule 65(b)(2) on February 6, 2025. Feb. 6, 2025 Minute Order. Plaintiffs, several coalitions of nonprofit organizations, have moved for a preliminary injunction granting similar relief as the TRO. ECF No. 40. Upon consideration of the parties’ briefs, ECF Nos. 40, 47, 49, an amicus brief from the American Center for Law and Justice, ECF No. 48, the oral argument held on February 20, 2025, Feb. 20, 2025 Minute Entry, and for the reasons explained below, the court will enter a preliminary injunction.

I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY

While most of the following factual background and procedural history was explained in the court’s opinion granting the TRO, ECF No. 30, the court recounts the details here for completeness and adds developments since the court’s February 3, 2025 hearing, TRO Hr’g, Nat’l Council of Nonprofits v. Off. of Mgmt. & Budget, No. 25-CV-239 (D.D.C. Feb. 3, 2025).

A. Office of Management and Budget Memorandum M-25-13

On January 27, 2025, Matthew J. Vaeth, Acting Director of OMB, issued a memorandum directing federal agencies to “complete a comprehensive analysis of all of their Federal financial assistance programs to identify programs, projects, and activities that may be implicated by any of the President’s executive orders.” Off. of Mgmt. & Budget, Exec. Off. of the President, Temporary Pause of Agency Grant, Loan, and Other Financial Assistance Programs (Jan. 27, 2025), https://perma.cc/69QB-VFG8 (“OMB Pause Memorandum,” or “M-25-13”), at 2. The memorandum stated that, “[i]n the interim, to the extent permissible under applicable law, Federal agencies must temporarily pause all activities related to [the] obligation or disbursement of all Federal financial assistance, and other relevant agency activities that may be implicated by the executive orders, including, but not limited to, financial assistance for foreign aid, nongovernmental organizations, DEI, woke gender ideology, and the green new deal.” Id. Additionally, the memorandum directed that “[e]ach agency must pause: (i) issuance of new awards; (ii) disbursement of Federal funds under all open awards; and (iii) other relevant agency actions that may be implicated by the executive orders, to the extent permissible by law.” Id.

The memorandum defined “Federal financial assistance” as: “(i) all forms of assistance listed in paragraphs (1) and (2) of the definition of this term at 2 [C.F.R. §] 200.1; and (ii) assistance received or administered by recipients or subrecipients of any type except for assistance received directly by individuals.” Id. ¶ 17. This includes all federal assistance in the form of grants, loans, loan guarantees, and insurance. Id. ¶ 18; see 2 C.F.R. § 200.1.2 As relevant executive orders, it listed:

▪ Protecting the American People Against Invasion (Jan. 20, 2025);

▪ Reevaluating and Realigning United States Foreign Aid (Jan. 20, 2025);

▪ Putting America First in International Environmental Agreements (Jan. 20, 2025);

▪ Unleashing American Energy (Jan. 20, 2025);

▪ Ending Radical and Wasteful Government DEI Programs and Preferencing (Jan. 20, 2025);

▪ Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government (Jan. 20, 2025); and

▪ Enforcing the Hyde Amendment (Jan. 24, 2025).

OMB Pause Memorandum, at 1-2.

The memorandum stated that “[t]he temporary pause [would] become effective on January 28, 2025 at 5:00 PM.” Id. at 2. During the pause, agencies were directed to “submit to OMB detailed information on any programs, projects[,] or activities subject to [the] pause” on or before February 10, 2025. Id. at 2.

B. Complaint, Emergency Hearing, and Administrative Stay

Shortly after noon on January 28, Plaintiffs brought this suit against OMB and Acting Director Vaeth arguing that OMB’s action violated the Administrative Procedure Act (“APA”), 5 U.S.C. § 701 et seq. ECF No. 1. Plaintiffs alleged that the implicated federal grants and funding “are the lifeblood of operations and programs for many . . . nonprofits, and [that] even a short pause in funding . . . could deprive people and communities of their life-saving services.” Id. ¶ 32. They argued that Defendants’ action was arbitrary and capricious, violated the First Amendment of the United States Constitution, and exceeded OMB’s statutory authority. Id. ¶¶ 43-61.

Along with their complaint, Plaintiffs sought a temporary restraining order “barring the OMB and all of its officers, employees, and agents from taking any steps to implement, apply, or enforce Memo M-25-13.” ECF No. 5, at 18. Defendants entered an appearance, ECF No. 9, and the court held an emergency hearing at 4:00 p.m. on January 28 to discern the parties’ positions with respect to the issuance of a brief administrative stay pending the resolution of Plaintiffs’ request for a TRO, Jan. 28, 2025 Minute Entry.

Given the extreme time constraints of the litigation and the magnitude of the legal issues, the court entered a brief administrative stay to permit the parties to fully brief the TRO motion and “buy[] the court time to deliberate.”3 ECF No. 13, at 3 (quoting United States v. Texas, 144 S. Ct. 797, 798 (2024) (Barrett, J., concurring)). The administrative stay was limited in scope and only prohibited Defendants “from implementing OMB Memorandum M-25-13 with respect to the disbursement of Federal funds under all open awards” until 5:00 p.m. on February 3, 2025. Id. at 4-5. The court also set a hearing on Plaintiffs’ TRO motion for 11:00 a.m. on February 3, 2025. Id. at 5.

C. Rescission of Memorandum M-25-13 and Aftermath

On January 29, the day after the court entered its administrative stay, OMB issued a new memorandum (“M-25-14”) that purported to rescind M-25-13. See ECF Nos. 18, 18-1. The new memorandum consisted of two sentences: “OMB Memorandum M-25-13 is rescinded. If you have questions about implementing the President’s Executive Orders, please contact your agency General Counsel.” ECF No. 18-1.

Shortly after this “rescission” was issued, White House Press Secretary Karoline Leavitt announced from her official social media account that the new memorandum was “NOT a rescission of the federal funding freeze.” Karoline Leavitt, X (formerly Twitter) (Jan. 29, 2025), https://perma.cc/99C4-5V6G. Instead, she stated that “[i]t [was] simply a rescission of [OMB memorandum M-25-13].” Id. She further explained that the purpose of the rescission was “[t]o end any confusion created by the court’s injunction.” Id. The entire post may be viewed below:

Image
Karoline Leavitt @PressSec
This is NOT a rescission of the federal funding freeze.

It is simply a rescission of the OMB memo.

Why? To end any confusion created by the court's injunction.

The President's EO's on federal funding remain in full force and effect, and will be rigorously implemented.

1:40 PM Jan 29, 2025


Id.4

D. Temporary Restraining Order Phase

On January 30, Defendants filed their opposition to Plaintiffs’ TRO motion and concurrently moved to dismiss the complaint for lack of subject matter jurisdiction. ECF Nos. 20, 21. Both motions were fully briefed by February 1. ECF Nos. 24, 25, 26.

On the morning of February 3, 2025, the court held a hearing on Plaintiffs’ motion for a TRO. Feb. 3, 2025 Minute Entry. At the conclusion of the hearing, the court explained that it was inclined to grant a TRO and deny Defendants’ motion to dismiss. Tr. of TRO Hr’g, Nat’l Council of Nonprofits, at 58:17-59:15, No. 25-CV-239 (D.D.C. Feb. 3, 2025). Pursuant to the court’s request, Plaintiffs submitted a proposed TRO order shortly after the hearing concluded, and Defendants responded to the proposed order by mid-afternoon.

Before the administrative stay expired at 5:00 p.m., the court issued a memorandum opinion and order granting Plaintiffs’ motion for a temporary restraining order. ECF No. 30. The court concluded that it had jurisdiction over Plaintiffs’ motion, that the case was not moot following the purported “rescission” of the OMB Pause Memorandum, and that Plaintiffs had met the heavy burden of showing that they were entitled to a temporary restraining order. Id. at 6-29. Specifically, the court found that Plaintiffs had demonstrated that they were likely to succeed on their arbitrary and capricious claim because “Defendants . . . offered no rational explanation for why they needed to freeze all federal financial assistance—with less than twenty-four-hours’ notice—to ‘safeguard valuable taxpayer resources.’” Id. at 23 (quoting OMB Pause Memorandum, at 1).5 The court further determined that Plaintiffs had produced evidence that they would suffer irreparable injury in the absence of emergency relief because “the funding freeze threaten[ed] the lifeline that keeps countless organizations operational.” Id. at 28. Finally, the court concluded that the “nationwide panic” and widespread chaos caused by the impending freeze tipped the public interest heavily in favor of a temporary restraining order. Id. at 28-29.

The order prohibited Defendants “from implementing, giving effect to, or reinstating under a different name the directives in OMB Memorandum M-25-13 with respect to the disbursement of Federal funds under all open awards.” ECF No. 30, at 29. Pursuant to the order, Defendants sent written notice “to all agencies to which OMB Memorandum M-25-13 was addressed” informing them of the temporary restraining order later that evening. ECF No. 39, at 1.

On February 6, the court set an expedited preliminary injunction briefing schedule and ordered the parties to appear for a hearing on February 20 at 11:00 a.m. Feb. 6, 2025 Minute Order. The court also extended the TRO for good cause until it could resolve Plaintiffs’ forthcoming preliminary injunction motion. Id.

E. Preliminary Injunction Phase

On February 11, Plaintiffs filed their motion for a preliminary injunction. ECF No. 40. Defendants filed their opposition on February 15, ECF No. 47, and Plaintiffs filed their reply on February 18, ECF No. 49.6

Some of Plaintiffs’ members submitted new declarations explaining that they have been able to access their previously allocated federal funds since the court’s entry of the TRO. See ECF Nos. 40-1 ¶ 3; 40-2 ¶ 6; 40-3 ¶ 4. Those declarants still maintain, however, that any additional pause in funding will have catastrophic or fatal consequences for their organizations. See ECF Nos. 40-1 ¶¶ 4-5; 40-2 ¶¶ 7-8; 40-3 ¶ 5.

On the morning of February 20, the court held a hearing on Plaintiffs’ motion for a preliminary injunction. Feb. 20, 2025 Minute Entry.

F. Parallel Litigation in the District of Rhode Island

On the same day Plaintiffs filed this suit, and several hours before memorandum M-25-13’s pause was to go into effect, twenty-two states and the District of Columbia filed suit in the U.S. District Court for the District of Rhode Island and sought a TRO to halt implementation of the memorandum. See Compl., New York v. Trump, No. 25-CV-39 (D.R.I. Jan. 28, 2025), ECF No. 1.

The district court held a hearing on January 29 at 3:00 p.m., after OMB had “rescinded” memorandum M-25-13. The court granted the States’ request and issued a TRO on January 31, 2025. TRO, New York, No. 25-CV-39 (D.R.I. Jan. 31, 2025), ECF No. 50. The restraining order prohibited the defendants (President Trump, OMB, and eleven federal agencies) from “paus[ing], freez[ing], imped[ing], block[ing], cancel[ing], or terminat[ing] [their] compliance with awards and obligations to provide federal financial assistance to the [plaintiff] States.” Id. at 11. The order also prohibited the defendants “from reissuing, adopting, implementing, or otherwise giving effect to the [OMB memorandum M-25-13] under any other name or title, . . . such as the continued implementation identified by the White House Press Secretary’s statement of January 29, 2025.” Id. at 12. Finally, the court directed the States to file their forthcoming motion for a preliminary injunction expeditiously. Id. at 11.

On the morning of February 3, the defendants filed a notice of compliance with the District of Rhode Island’s TRO. Notice of Compliance with Court’s TRO, New York, No. 25-CV-39 (D.R.I. Feb. 3, 2025), ECF No. 51. In it, the defendants explained that they had provided written notice to all defendant agencies on January 31 to inform them of the TRO and instruct them to comply with its restrictions. Id. ¶ 1. The defendants also notified the court that they believed certain terms of the TRO “constitute[d] significant intrusions on the Executive Branch’s lawful authorities and the separation of powers.” Id. ¶ 2.

The court subsequently set a briefing schedule on the States’ motion for a preliminary injunction. Text Order, New York, No. 25-CV-39 (D.R.I. Feb. 3, 2025). On February 6, the court held a status conference and extended the duration of its TRO until it could rule on the preliminary injunction motion. Text Order, New York, No. 25-CV-39 (D.R.I. Feb. 6, 2025). The next day, the States filed an emergency motion to enforce the TRO, citing evidence that they “continue[d] to be denied access to federal funds.” Mot. for Enforcement of the TRO, New York, No. 25-CV-39 (D.R.I. Feb. 7, 2025), ECF No. 66. The defendants opposed, arguing that their actions “d[id] not run afoul of the Court’s injunction, or at least not a ‘clear and unambiguous command’ in the Court’s injunction.” Opp’n to Pls.’ Mot. to Enforce TRO, New York, No. 25-CV-39 (D.R.I. Feb. 9, 2025), ECF No. 70. On February 10, the court granted the States’ motion and ordered the defendants to “immediately restore frozen funding,” “end any federal funding pause,” and “take every step necessary to effectuate the TRO” during its pendency. Order, New York, No. 25-CV-39 (D.R.I. Feb. 10, 2025), ECF No. 96.

Even though the court had not ruled on the still-pending motion for a preliminary injunction, the defendants appealed later that day. Notice of Appeal, New York, No. 25-CV-39 (D.R.I. Feb. 10, 2025), ECF No. 98. They sought (1) review of the district court’s TRO order and enforcement orders, and (2) an administrative stay of the district court’s rulings pending the appeal. Emergency Mot. for Immediate Administrative Stay, New York v. Trump, No. 23-1138 (1st Cir. Feb. 10, 2025). The First Circuit assumed that it had jurisdiction over the appeal and unanimously denied the request for an administrative stay without prejudice. Order, New York, No. 23-1138 (1st Cir. Feb. 11, 2025). It expressed uncertainty as to whether such an administrative stay could issue and noted that “the defendants d[id] not cite any authority in support of their administrative stay request or identify any harm related to a specific funding action or actions that they w[ould] face without their requested administrative stay.” Id. The appellate court did not address the merits of the appeal. Id. The defendants then moved to voluntarily dismiss their appeal, Mot. to Voluntarily Dismiss Appeal, New York, No. 23-1138 (1st Cir. Feb. 13, 2025), which the court granted on February 13. Judgment, New York, No. 23-1138 (1st Cir. Feb. 13, 2025).

On February 21, the District of Rhode Island held a preliminary injunction hearing. The court took the States’ motion under advisement but “reiterate[d] that the previously entered TRO [remained] in full force and effect.” Minute Entry, New York, No. 25-CV-39 (D.R.I. Feb. 21, 2025). Litigation remains ongoing.

II. DISCUSSION

A. Jurisdiction


The factual situation has shifted somewhat since the court entered its TRO, and Defendants again press their jurisdictional arguments. While the initial funding freeze has begun to thaw, the court concludes that it still retains jurisdiction.

1. Standing

As an initial matter, there is no question that Plaintiffs had standing when they initially brought their complaint. ECF No. 30, at 6-13; see Garcia v. U.S. Citizenship & Immgr. Servs., 168 F. Supp. 3d 50, 65 (D.D.C. 2016) (explaining that standing “is concerned with the presence of injury, causation, and redressability at the time a complaint is filed”). As the court explained in its TRO opinion, Plaintiffs had satisfied each of the three standing requirements: (1) a concrete and particularized injury in fact; (2) a causal connection linking the injury and the challenged conduct; and (3) a likelihood that a favorable court decision will redress the injury. ECF No. 30, at 6-7 (quoting Lujan v. Defs. of Wildlife, 504 U.S. 555, 560-61 (1992)). While that alone is sufficient to confer standing, the court pauses to note that standing persists.

a. Injury in fact

Plaintiffs have demonstrated that “even a temporary pause in funding to their members . . . would destroy their ability to provide [critical] services.” ECF No. 30, at 7; see ECF No. 1 ¶¶ 33-34, 36-40. Many, if not all, of Plaintiffs’ members “need weekly injections of federal funds in order to continue operating.” ECF No. 30, at 8; see, e.g., ECF No. 24-7 ¶¶ 20-21. Some have employees who “live paycheck to paycheck, meaning that a single missed payment could prevent them from buying groceries or paying rent.” ECF No. 30, at 9 (internal quotation marks omitted); see ECF No. 24-4 ¶ 7. Others had begun to feel the effects of the freeze even before it was supposed to go into effect: one tribal organization was forced to preemptively lay off two employees on January 28. ECF No. 30, at 9; see ECF No. 24-5 ¶ 13. Plaintiffs also demonstrated constitutional injury because “Defendants [allegedly] singled out their funding programs (in other words, their economic lifelines) based on their exercise of speech and association.” ECF No. 30, at 8.

Defendants now try to frame the issue as one of Plaintiffs’ “standing to seek prospective relief.” ECF No. 47, at 11. The court reminds Defendants that the injunctive relief currently in place was issued to temporarily stave off imminent, irreparable harm. Facts have certainly evolved since then, see infra Part II.A.2, but Defendants cannot pretend that the nationwide chaos and paralysis from two weeks ago is some distant memory with no bearing on this case. The relief Plaintiffs now seek is a more durable version of the relief they sought then, when their members were on the brink of extinction. In sum, Plaintiffs have marshalled significant evidence indicating that the funding freeze would be economically catastrophic—and in some circumstances, fatal—to their members. That is sufficient to show an injury-in-fact.

b. Causation

The court previously rejected Defendants’ attempts to break the causal chain between the funding freeze and the OMB Pause Memorandum. ECF No. 30, at 9-12. Plaintiffs convincingly demonstrated that the memorandum—not some other cause—triggered the shutting down of federal funding portals and the suspension of assistance payments. Id. While Defendants have tried to attribute the pauses to individual agency discretion, those pauses did not occur until after the memorandum was issued.

In opposing the TRO, Defendants cited two cases, ECF No. 21-1, at 10-11, but the court was not persuaded then, and it remains unpersuaded. The first featured an executive order that “d[id] not require any action from federal agencies.” Louisiana ex rel. Landry v. Biden, 64 F.4th 674, 681 (5th Cir. 2023). Instead, the order allowed agencies to individually determine whether the guidance applied to their activities. Id. For that reason, causation in Louisiana “hinge[d] on the independent choices of [a] regulated third party” and was not traceable to the defendant. Center for Law & Educ. v. Dep’t of Educ., 396 F.3d 1152, 1161 (D.C. Cir. 2005) (quoting Nat’l Wrestling Coaches Ass’n v. Dep’t of Educ., 366 F.3d 930, 938 (D.C. Cir. 2004), abrogated on other grounds by Cohen v. United States, 650 F.3d 717 (D.C. Cir. 2011) (en banc)). In contrast, the OMB Pause Memorandum was a clear command. It emphatically stated that all federal agencies “must temporarily pause all activities related to [the] obligation or disbursement of all Federal financial assistance.” OMB Pause Memorandum, at 2. That was a directive, not a suggestion. Just two paragraphs later, it reiterated that agencies “must pause . . . disbursement of Federal funds under all open awards.” Id. And in the penultimate paragraph, it stated that “OMB may grant exceptions allowing Federal agencies to issue new awards or take other actions on a case-by-case basis.” Id. (emphasis added). On its face, the memorandum does not read like a guidance that leaves funding decisions solely in the hands of independent, third-party agencies.

The second case, on which Defendants no longer rely, was also inapposite. In Jacobson v. Florida Secretary of State, 974 F.3d 1236 (11th Cir. 2020), the plaintiffs sought to change the way elections officials were listing gubernatorial candidates, but they had sued a government actor with no actual control over those officials. Id. at 1253. The elections officials were answerable only to voters, not the defendant. Id. Here, however, Defendants try to build their case on the exact opposite premise: that OMB does exercise control over federal financial policies. See ECF No. 21-1, at 16-20. Both Louisiana and Jacobson are therefore inapplicable.

Further undermining Defendants’ position, federal agencies clearly behaved as if the memorandum caused the freeze. In the immediate aftermath of the court’s administrative stay on January 28, the Environmental Protection Agency continued to pause funding disbursements explicitly based on the memorandum. See ECF No. 24-1, at 7 (explaining that the agency was still “working diligently to implement [OMB]’s memorandum” and was therefore “temporarily pausing all activities related to the obligation or disbursement of EPA Federal financial assistance” and working closely “with OMB” to do so).

Undeterred, Defendants vigorously challenge causation again at the preliminary-injunction stage. They start by rehashing the independent-agency theory, claiming that the memorandum “did not itself temporarily pause any federal financial assistance.” ECF No. 47, at 13. For that to be true, Defendants would have the court believe that countless federal agencies, none of which had acted to cut off financial assistance before January 28, suddenly began exercising their own discretion to suspend funding across the board at the exact same time. That would be a remarkable—and unfathomable—coincidence. That this uniform freeze occurred just hours after the memorandum’s issuance would be quite the happenstance, too. Indeed, the record belies Defendants’ assertions. It reflects that after OMB issued its memorandum on January 27, agencies immediately began freezing funds, and after this court entered its TRO, some of those funds were released. See, e.g., ECF Nos. 40-3 ¶ 4 (organization able to draw down funds on February 4, one day after entry of the TRO); 40-1 ¶ 3 (organization able to draw down funds on February 5, two days after entry of the TRO); 40-2 ¶ 6 (organization received funds on February 6, three days after entry of the TRO).

Defendants try to downplay the fact that the freeze began to thaw after the court entered its TRO. They claim that this “could equally be because such funds were not intended to be paused under the OMB Memo and OMB Guidance, or because of a broader court order entered by the district court in Rhode Island.” ECF No. 47, at 13. But this argument requires the exact same coincidental assumptions as above, just in reverse. And it contradicts the record, which indicates that agencies explicitly relied on the memorandum when responding to funding inquiries. See ECF No. 24-1, at 7. Adopting Defendants’ view would require reading the memorandum differently than how it was written. Its directive was broad and mandatory, and that is exactly how the agencies interpreted it. See infra Part II.A.2.a.

Defendants also argue that the memorandum “d[id] not determine which funds or grants should be paused” and instead “require[d] that agencies make that determination, consistent with their own authorities.” ECF No. 47, at 13. In a manner of speaking, Defendants are right that the memorandum did not identify specific funds to be paused. Instead, it simply paused them all. OMB Pause Memorandum, at 2. Defendants cannot show that this directive left any room for agency discretion, especially on the nearly nonexistent timetable it provided. Agencies were not given an option on whether to continue honoring their payment obligations; they simply had to stop. And even if the agencies thought they had discretion to act, they were given roughly half a day to evaluate up to $3 trillion in grants, loans, and other programs. That is not discretion.

When Plaintiffs filed suit, they alleged that Defendants had illegally ordered all federal agencies to suspend payments on open awards. Plaintiffs provided evidence that those agencies only started freezing funds after the memorandum was issued and—in some cases—expressly relied on the memorandum to do so. Within days of this court’s TRO (and Defendants’ written notice to all federal agencies), payments began to resume. Defendants ask the court to overlook the simplest, most logical explanation for that sequence of events. The court declines to do so.

c. Redressability

Redressability is closely related to causation, and Plaintiffs have satisfied it. Defendants claim that “[Plaintiffs’] funding is not administered by OMB” and that an injunction against it “would not give [them] legally enforceable protection from the allegedly imminent harm.” ECF No. 47, at 14 (quoting Haalend v. Brackeen, 599 U.S. 255, 293 (2023)).

But Plaintiffs seek an injunction barring Defendants from directing agencies to freeze federal funding nationwide in a blanket fashion. Prelim. Inj. Hr’g, Nat’l Council of Nonprofits, No. 25-CV-239 (Feb. 20, 2025). As the court previously explained, a ruling in Plaintiffs’ favor would force agencies “to behave as if the memorandum were never issued.” ECF No. 30, at 13. Any pauses premised on the memorandum would cease, thus granting Plaintiffs significant relief. Whether individual agencies later exercise their individual discretion to stop funding on another basis does not defeat redressability as it pertains to the OMB Pause Memorandum.

2. Mootness

Mootness, sometimes defined as “standing set in a time frame,” asks whether a case continues to present a live controversy as it progresses. U.S. Parole Comm’n v. Geraghty, 445 U.S. 388, 397 (1980) (quoting Henry P. Monaghan, Constitutional Adjudication: The Who and When, 82 Yale L.J. 1363, 1384 (1973)). As the court explained in its earlier opinion, despite the purported “recission” of the OMB Pause Memorandum, the case was not moot at the time the court entered its TRO. ECF No. 30, at 13-19. While Defendants continue to argue mootness in light of recent factual developments, the court’s previous analysis still applies today.

a. Rescission of the memorandum

Defendants begin by again relying on the rescission of the OMB Pause Memorandum, which occurred on January 29. ECF No. 47, at 8. That “rescission,” however, had already taken place when Defendants last made this same argument. The court rejected the claim then, and it rejects the claim now.

First, the doctrine of voluntary cessation still applies. A party’s decision to stop “a challenged practice does not deprive a federal court of its power to determine [its] legality.” Friends of the Earth, Inc. v. Laidlaw Env’t Servs. (TOC), Inc., 528 U.S. 167, 189 (2000) (quoting City of Mesquite v. Aladdin’s Castle, Inc., 455 U.S. 283, 289 (1982)). This doctrine exists to protect plaintiffs and prevent a defendant from “return[ing] to [its] old ways” as soon as a case gets dismissed. Id. (quoting City of Mesquite, 455 U.S. at 289). To overcome it, a defendant must meet a heavy burden: it must show that it is “absolutely clear [that] the allegedly wrongful behavior [cannot] reasonably be expected to recur.” Pub. Citizen, Inc. v. Fed. Energy Reg. Comm’n, 92 F.4th 1124, 1128 (D.C. Cir. 2024) (emphasis added) (quoting Friends of the Earth, Inc., 528 U.S. at 189).

Rescinding the OMB Pause Memorandum did not moot the case because Defendants could not—and still cannot—show that they will not “resume the challenged activity.” Id. As the court previously observed, the White House Press Secretary appeared to completely contradict the act of rescission by expressly stating that it was “NOT a rescission of the federal funding freeze.” Karoline Leavitt, X (formerly Twitter) (Jan. 29, 2025), https://perma.cc/99C4-5V6G. By any reading of the Press Secretary’s remarks, the memorandum’s retraction was an empty gesture. At best, it was meaningless. At worst, it was a brazen attempt to deprive the court of jurisdiction without actually altering course. See Pub. Citizen, Inc., 92 F.4th at 1128 (explaining that the voluntary-cessation doctrine applies with greater force when a party is suspected of “manipulating the judicial process through the false pretense of singlehandedly ending a dispute” (internal quotation marks omitted) (quoting Guedes v. Bureau of Alcohol, Tobacco, Firearms & Explosives, 920 F.3d 1, 15 (D.C. Cir. 2019) (per curiam))). Because Plaintiffs’ members were still being frozen out of their funding in the wake of the purported “rescission,” see ECF Nos. 24-4 ¶ 12; 24-5 ¶ 24; 24-11 ¶ 19, “it appears that OMB sought to overcome a judicially imposed obstacle without . . . ceasing the challenged conduct.” ECF No. 30, at 16.7

Defendants and Amicus now say that factual developments have made the voluntary-cessation doctrine inapplicable. ECF No. 47, at 9-10. Specifically, they say that “there is no reason to think OMB [will] reissue the challenged Memo” because the President’s executive orders—which Plaintiffs do not challenge—remain in place. Id. at 10; see ECF No. 48, at 4 (Amicus arguing that the “executive orders related to federal funding” independently “order[ed] federal agencies to engage in certain specified pauses”). In other words, the memorandum would have no added benefit. But this argument ignores the fact that the effects of the OMB Pause Memorandum and the President’s executive orders were not coextensive. At the TRO hearing, Defendants could not explain all the frozen funding by relying on the executive orders alone. See ECF No. 30, at 18 (“Plaintiffs have provided evidence that the scope of frozen funds appears to extend far beyond the reach of the executive orders[.]”), 19 (“At oral argument, when asked about another declarant who was receiving a grant from the National Science Foundation, Defendants could not give a clear answer as to why that recipient would be denied funds pursuant to the executive orders.” (citation omitted)). Defendants insist that this overreach may have been because agencies overzealously implemented the freeze. But that is a problem of Defendants’ own creation. Their memo was written, interpreted, and executed as a blanket pause. See, e.g., Tr. of TRO Hr’g, at 16:1-5, Nat’l Council of Nonprofits, No. 25-CV-239 (D.D.C. Feb. 3, 2025) (“[T]he way that the OMB order has been implemented in many cases . . . is [not by] pausing individual grants but by freezing the platforms, the online portals[.]”). Defendants cannot shift the blame onto federal agencies because those agencies followed Defendants’ own orders.

Attempting to put the agencies’ real-world interpretations aside, Defendants assert that the memorandum’s language was clearly limited only to activities covered by the seven executive orders referenced in the memorandum. See Tr. of Prelim. Inj. Hr’g, at 26:25-29:17, Nat’l Council of Nonprofits, No. 25-CV-239 (D.D.C. Feb. 20, 2025). The court is unconvinced for several reasons. The memorandum’s primary directive (“must temporarily pause”) targeted “all activities related to [the] obligation or disbursement of all Federal financial assistance, and other relevant agency activities that may be implicated by the executive orders, including, but not limited to, financial assistance for foreign aid, nongovernmental organizations, DEI, woke gender ideology, and the green new deal.” OMB Pause Memorandum, at 2. OMB’s decision to separate the first and second clauses indicated that they were to be treated as distinct categories for the pause. If both clauses were meant to be limited to the executive orders, it is not clear why OMB would distinguish “all activities related to obligation or disbursement” from “other relevant agency activities.” Id. Conceivably, OMB would have simply instructed agencies to pause all funding activities related to the executive orders and leave it at that.

Furthermore, the whole purpose of the pause was to give agencies time “to identify programs, projects, and activities that may be implicated by any of the President’s executive orders.” Id. (emphasis added). The pause was to apply “[i]n the interim”—in other words, while that identification took place. It would make little sense for agencies to only pause activities associated with the executive orders while evaluating what activities are even associated with the executive orders in the first place. The narrower reading that Defendants endorse would require agencies to already know what activities “may be implicated” by the executive orders. For the memorandum’s order of operations to be logical, then, the court would need to read it the way Plaintiffs do: OMB told agencies to assess funding for consistency with the President’s executive orders and, “[i]n the interim,” “temporarily pause all activities related to [the] obligation or disbursement of Federal financial assistance” while that assessment was underway. Id.

Additionally, if the memorandum’s language were obviously limited to the executive orders, the court does not understand why OMB included a footnote carving out Social Security and Medicare, see id. at 1 n.2, or subsequently issued an entirely new document clarifying the original directive, ECF No. 11-1. None of the executive orders addresses Social Security or Medicare at all. If it were apparent that the pause did not extend beyond the executive orders, the footnote is entirely unnecessary. And as for the subsequent guidance, it does not make sense for Defendants to claim that an initial instruction is unambiguous but then feel a need to clarify it only hours later.

In sum, the doctrine of voluntary cessation still applies. Defendants have not made it “absolutely clear” that they will refrain from resuming the challenged activity given their post-complaint actions and overly restrictive reading of the memorandum’s language. Pub. Citizen, Inc., 92 F.4th at 1128.

b. Resumption of funding

Second, Defendants try to argue that the gradual thawing of the freeze indicates mootness. ECF No. 47, at 9-11. The court disagrees. It is true that some of Plaintiffs’ members are now receiving federal funds again, but that does not render their case, or their request for injunctive relief, moot.

At the preliminary injunction stage, Defendants cannot simply “claim that the need for an injunction is now moot because [they have] ‘ceased [their] wrongful conduct.’” Costa v. Bazron, 464 F. Supp. 3d 132, 141 (D.D.C. 2020) (quoting Taylor v. Resol. Tr. Corp., 56 F.3d 1497, (D.C. Cir. 1995)). This rings especially true when the cessation “follow[s] the entry of a TRO.” Id. The “court’s power to grant injunctive relief survives discontinuance of the illegal conduct” because the “purpose . . . is to prevent future violations.” Dep’t of Just. v. Daniel Chapter One, 89 F. Supp. 3d 132, 143 (D.D.C. 2015) (alteration in original) (quoting United States v. W.T. Grant Co., 345 U.S. 629, 633 (1953)).

Defendants instructed agencies to disregard the directives of the memorandum, as they were required to do so by two different courts’ orders. See ECF No. 30, at 29 (directing Defendants to issue written notice to all agencies); ECF No. 39-1 (Defendants’ written notice); TRO, New York, No. 25-CV-39 (D.R.I. Jan. 31, 2025), ECF No. 50. But Defendants cannot now rely on this court-ordered compliance to argue that a court order is unnecessary. As Plaintiffs point out, and as other judges of this court have recognized, adopting Defendants’ position would mean that no TRO could ever become a preliminary injunction. See Costa, 464 F. Supp. 3d at 142 (“If compliance with the terms of a TRO were sufficient to defeat entry of a preliminary injunction, few—if any—cases would make it past the TRO stage.”).

Defendants blithely suggest that if they were to revive or reissue the OMB Pause Memorandum at some future point in time, Plaintiffs could simply “file another motion for preliminary relief.” ECF No. 47, at 11. This proposal completely disregards the mountain of evidence Plaintiffs presented showing that even the threat of a funding freeze was enough to send countless organizations into complete disarray. Hours before the original pause was scheduled to start, organizations were already laying off staff or shuttering programs. See, e.g., ECF Nos. 24-5 ¶ 13; 24-7 ¶¶ 20-21. In some cases, this was anticipatory; in others, it was because organizations were already being frozen out of funding portals. See ECF Nos. 24-8 ¶¶ 8-9; 24-6 ¶ 15; 24-7 ¶ 13; 24-8 ¶ 9. Defendants’ assumption that Plaintiffs can easily rush back before the court for injunctive relief before catastrophe ensues is, quite simply, divorced from reality and the record. Indeed, while turning off funding streams appears to have been alarmingly easy, turning them back on has proven much more difficult. See ECF No. 40-2 ¶ 6 (explaining that it took three days to receive funding after entry of the TRO); Prelim. Inj. Hr’g, at 3:9-10, Nat’l Council of Nonprofits, No. 25-CV-239 (Feb. 20, 2025) (“Unfreezing of funds in response to that order has not always been smooth; in some cases, we think maybe imperfect and incomplete.”).

Additionally, other intervening developments since the court issued its TRO seem to increase the urgency of injunctive relief. On February 10, the judge in the District of Rhode Island case was forced to issue an order enforcing its TRO after the States “presented evidence . . . that the Defendants in some cases have continued to improperly freeze federal funds and refused to resume disbursement of appropriated federal funds.” Order, New York, No. 25-CV-39 (D.R.I. Feb. 10, 2025), ECF No. 96. The court did not mince words, concluding that “[t]hese pauses in funding violate the plain text of the TRO.” Id. Defendants cannot convincingly tell this court that there is no longer a need for injunctive relief after they were found to be in violation of another court’s order.

For all these reasons, the court remains unpersuaded by Defendants’ mootness arguments. To be sure, the government is normally entitled to a presumption of good faith on voluntary cessation. Pub. Citizen, Inc., 92 F.4th at 1128-29 (quoting Clarke v. United States, 915 F.2d 699, 705 (D.C. Cir. 1990) (en banc)). But the court will not confer that presumption when the government says one thing while expressly doing another. Karoline Leavitt, X (formerly Twitter) (Jan. 29, 2025), https://perma.cc/99C4-5V6G. And it will not reward parties who change appearances without changing conduct.

3. Ripeness

At the preliminary injunction stage, Defendants raise a new jurisdictional argument based on ripeness. They claim that Plaintiffs’ claims are currently “too amorphous” for judicial review, and that the court should delay adjudication until further factual developments. ECF No. 47, at 14.8

Under the ripeness doctrine, courts conduct a two-pronged inquiry that evaluates (1) “the fitness of the issues for judicial decision,” and (2) “the hardship to the parties of withholding court consideration.” Andrade v. Lauer, 729 F.2d 1475, 1480 (D.C. Cir. 1984) (quoting Abbott Lab’ys v. Gardner, 387 U.S. 136, 149 (1967), abrogated on other grounds by Califano v. Sanders, 430 U.S. 99 (1977)). But when “a threatened injury is sufficiently ‘imminent’ to establish standing, the constitutional requirements of the ripeness doctrine will necessarily be satisfied.” Nat’l Treasury Emps. Union v. United States, 101 F.3d 1423, 1428 (D.C. Cir. 1996).

Plaintiffs have already established concrete, particularized, and non-speculative injuries—injuries that had devastating effects, persisted after the OMB Pause Memorandum was stayed, and loom over Plaintiffs to this day. In arguing to the contrary, Defendants ask the court to ignore the fact that agencies continued implementing OMB’s freeze or that the District of Rhode Island had to enforce its TRO mere days after it was entered. In the instant litigation, the only reason that harm stopped was because of injunctive relief issued by this court—relief that Defendants insist is unnecessary. Defendants’ ripeness arguments, like their mootness arguments, wholly disregard the factual circumstances of this case and its context.

B. Preliminary Injunction

While they differ in duration, temporary restraining orders and preliminary injunctions are subject to the same substantive legal standards. See, e.g., Singh v. Carter, 168 F. Supp. 3d 216, 223 (D.D.C. 2016). Courts may either grant a preliminary injunction pursuant to Federal Rule of Civil Procedure 65(c) or, in APA cases, may “issue all necessary and appropriate process to . . . preserve status or rights pending conclusion of the review proceedings” when doing so is “necessary to prevent irreparable injury.” 5 U.S.C. § 705. Both provisions provide a mechanism for issuing injunctive relief and operate under the same four-factor test. District of Columbia v. U.S. Dep’t of Agric., 444 F. Supp. 3d 1, 15 (D.D.C. 2020).

To obtain a preliminary injunction, “the moving party must show (1) a substantial likelihood of success on the merits, (2) that it would suffer irreparable injury if the injunction were not granted, (3) that an injunction would not substantially injure other interested parties, and (4) that the public interest would be furthered by the injunction.” Chaplaincy of Full Gospel Churches v. England, 454 F.3d 290, 297 (D.C. Cir. 2006).

These four considerations are factors, not elements. “A district court must ‘balance the strengths of the requesting party’s arguments in each of the four required areas.’” Id. (quoting CityFed Fin. Corp. v. Off. of Thrift Supervision, 58 F.3d 738, 747 (D.C. Cir. 1995)). When a government entity is a party to the case, the third and fourth factors merge. Pursuing Am.’s Greatness v. Fed. Election Comm’n, 831 F.3d 500, 511 (D.C. Cir. 2016).

Prior to the Supreme Court’s decision in Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008), courts in this Circuit tended to employ a “sliding scale” method in which “a strong showing on one factor could make up for a weaker showing on another.” Sherley v. Sebelius, 644 F.3d 388, 392 (D.C. Cir. 2011). While the D.C. Circuit has considered abandoning the sliding-scale method for one that treats the substantial likelihood prong as “an independent, free-standing requirement,” id. at 393, it has yet to decide one way or the other, see Changji Esquel Textile Co. v. Raimondo, 40 F.4th 716, 726 (D.C. Cir. 2022). At the very least, however, the plaintiff must present a “serious legal question on the merits.” Raimondo, 40 F.4th at 726 (quoting Sherley, 644 F.3d at 398). Given the ambiguity with respect to the sliding-scale approach, the court will consider all factors and delve into their relative weight only if it would affect the outcome. See Costa, 456 F. Supp. 3d at 133.
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Re: Anti-Anti-Nazi Barbarian Hordes are Knocking Down the Ga

Postby admin » Tue Apr 01, 2025 11:49 pm

Part 2 of 2

1. Likelihood of Success on the Merits

On the merits, Defendants largely repeat the same arguments they made at the TRO stage. See ECF No. 47, at 14-16 (final agency action), 25-31 (arbitrary and capricious), 31-34 (statutory authority), 34-36 (First Amendment). The court begins by addressing OMB’s guidance document, which the parties discussed at length in their preliminary injunction briefing and at oral argument. See ECF No. 47, at 20-25; ECF No. 49, at 4-6; Prelim. Inj. Hr’g, at 6:19-9:14, 29:21-32:24, Nat’l Council of Nonprofits, No. 25-CV-239 (D.D.C. Feb. 20, 2025). It then turns to final agency action, followed by the substantive merits of Plaintiffs’ three claims.

a. The role of the OMB Guidance

Defendants spill considerable ink about OMB’s issuance of a guidance document, ECF No. 11-1 (“OMB Guidance Document”), which supposedly limited the scope of the OMB Pause Memorandum, see ECF No. 47, at 20-25. They assert that the original memorandum, when read in tandem with the OMB Guidance Document, stops short of unlawful agency action. Id. at 21 (noting the OMB Guidance Document’s statement that “the pause does not apply across-the-board” and “is expressly limited to programs, projects, and activities implicated by the President’s Executive Orders”). This argument sounds persuasive in theory but clashes with how Defendants’ directives were actually written and implemented.

As an initial matter, the language of the OMB Guidance Document appears to contradict that of the original memorandum. The guidance document sought to carve out numerous programs and portray the initial command as much more limited, but the original memorandum mandated (in bold typeface, no less) that all federal agencies “must temporarily pause all activities related to [the] obligation or disbursement of all Federal financial assistance.” OMB Pause Memorandum. It also required agencies to stop the “disbursement of Federal funds under all open awards.” Id. (emphasis added). As the court explained previously, supra Part II.A.2.a, this language conveyed a clear directive to implement a blanket pause of federal financial assistance. That flatly contravenes the OMB Guidance Document’s pronouncement that the pause “d[id] not apply across-the-board.” OMB Guidance Document, at 1.

Furthermore, regardless of how Defendants would have liked their guidance to apply, that is a far cry from how it was administered in practice. As far as the parties and this court are aware, the guidance was issued at some point on January 28 (the same day the funding freeze was to take effect). Plaintiffs only received a copy of the guidance around 1:30 p.m., see ECF No. 11, at 2, and even Defendants did not know exactly when it was originally issued or distributed to federal agencies, Tr. of Prelim. Inj. Hr’g, at 25:5-9, Nat’l Council of Nonprofits, No. 25-CV-239 (Feb. 20, 2025). Under the most generous viewing of the case’s chronology, agencies had maybe four hours (but probably fewer) to actualize the OMB Guidance Document. Clearly, that was not enough time.9 Agencies still implemented the original memorandum as written. For example, despite the guidance’s attempt to carve out “program[s] that provide[] direct benefits to individuals,” OMB Guidance Document, at 1, financial assistance for such programs was still suspended, see ECF Nos. 24-5 ¶¶ 14-16; 27-1 ¶¶ 4-5. The guidance also exempted “[f]unds for small businesses” and “Head Start” payments, OMB Guidance Document, at 2, but those fell victim to the freeze, too, see ECF Nos. 24-3, at 74; 24-6. Defendants cannot rely on the OMB Guidance Document as a saving grace when it had virtually no effect on the ground.

This theme—that Plaintiffs are trying to enjoin a far-reaching version of the OMB Pause Memorandum that never existed—pervades all of Defendants’ briefing and argument. See ECF No. 47, at 10 (mootness), 13 (causation), 20-25 (role of the OMB Guidance Document); 27 (arbitrary and capricious). But Defendants cannot take a memorandum that was drafted broadly, interpreted expansively, and implemented categorically and fault Plaintiffs for “overreading” that directive.

b. Final agency action

Defendants, now joined by Amicus, again dispute whether the OMB Pause Memorandum was final agency action. Like before, the court is unpersuaded.

Finality is a prerequisite to the judicial review of an APA claim. See 5 U.S.C. § 704. Agency actions, as a general matter, must be “circumscribed [and] discrete.” Norton v. S. Utah Wilderness All., 542 U.S. 55, 62 (2004). Final agency action, in particular, “must mark the consummation of the agency’s decisionmaking process” and determine “rights or obligations . . . from which legal consequences will flow.” Bennett v. Spear, 520 U.S. 154, 177-78 (1997) (internal quotation marks omitted) (first quoting Chicago & S. Air Lines, Inc. v. Waterman S.S. Corp., 333 U.S. 103, 113 (1948), then quoting Port of Boston Marine Terminal Ass’n v. Rederiaktiebolaget Transatlantic, 400 U.S. 62, 71 (1970)). The APA does not, for example, allow a court to review an agency’s “day-to-day operations.” Lujan v. Nat’l Wildlife Fed’n, 497 U.S. 871, 899 (1990).

Echoing points from their causation argument, Defendants claim that any instruction from OMB could not have been final because it was the individual agencies that carried out the funding freeze. To the extent this repeats the causation analysis, the court has already addressed it. See supra Part II.A.1.b.

Defendants and Amicus further accuse Plaintiffs of improperly advancing a “‘broad programmatic attack’ on an agency’s operations” by targeting a policy “consisting [principally] of . . . many individual actions.” ECF No. 48, at 5 (second alteration in original) (first quoting Norton, 542 U.S. at 64, then quoting Nat’l Wildlife Fed’n, 497 U.S. at 892-93); see ECF No. 47, at 15-16. But Plaintiffs only challenge one specific act by OMB: ordering a nationwide pause on federal financial assistance. And, as explained, supra Part II.B.1.a, Defendants and Amicus cannot rely on a theoretical version or application of OMB’s directives. The initial memorandum was drafted and interpreted broadly in accordance with its text, and what little clarity the guidance offered—if any—came far too late. As the court explained in its earlier opinion, the OMB Pause Memorandum issued a mandatory command to other federal agencies that produced legal consequences for Plaintiffs and others. See ECF No. 30, at 21-23.

c. Arbitrary and capricious

Under the APA, a court must “hold unlawful and set aside agency action, findings, and conclusions” that are “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.” 5 U.S.C. § 706(2)(A). “The scope of review under the ‘arbitrary and capricious’ standard is narrow and a court is not to substitute its judgment for that of the agency.” Motor Vehicle Mfrs. Ass’n of the U.S., Inc. v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983). To pass muster, the agency “must examine the relevant data and articulate a satisfactory explanation for its action[,] including a ‘rational connection between the facts found and the choice made.’” Id. (quoting Burlington Truck Lines v. United States, 371 U.S. 156, 168 (1962)). Agency action is generally deemed unlawful if it “has relied on factors which Congress has not intended it to consider, entirely failed to consider an important aspect of the problem, offered an explanation for its decision that runs counter to the evidence before the agency, or is so implausible that it could not be ascribed to a difference in view or the product of agency expertise.” Id.

The arbitrary-and-capricious review at this stage of the litigation remains largely unchanged from the court’s earlier opinion. The touchstone of this inquiry is rationality, and Defendants’ actions flunk that test. Defendants still cannot provide a reasonable explanation for why they needed to freeze all federal financial assistance in less than a day to “safeguard valuable taxpayer resources.” OMB Pause Memorandum, at 1. Evaluating funding priorities can be done without needing to starve citizens or deny critical health services. See, e.g., ECF Nos. 24-4 ¶ 6; 24-11 ¶¶ 6-7. The potential $3 trillion in financial assistance implicated by the freeze is a “breathtakingly large sum of money to suspend practically overnight.” ECF No. 30, at 24. And “[r]ather than taking a measured approach to identify purportedly wasteful spending, Defendants cut the fuel supply to a vast, complicated, nationwide machine—seemingly without any consideration for the consequences of that decision.” Id. Doing so was not—and could never be—rational, especially when the decision was made without grappling with its catastrophic effects or the logistical nightmare of its implementation.10 See Bus. Roundtable v. Sec. & Exch. Comm’n, 647 F.3d 1144, 1148 (D.C. Cir. 2011) (explaining that an agency’s failure to “apprise itself . . . of the economic consequences” of potential action is “arbitrary and capricious and not in accordance with law” (quoting Chamber of Com. of the U.S. v. Sec. & Exch. Comm’n, 412 F.3d 133, 144 (D.C. Cir. 2005))). Defendants essentially adopted a “freeze first, ask questions later” approach that “entirely failed to consider [multiple] important aspect[s] of the problem.” Motor Vehicle Mfrs. Ass’n, 463 U.S. at 43.11

Defendants also ignored significant reliance interests. Plaintiffs—who only challenge the pausing of already allocated funds—produced substantial evidence that numerous organizations need consistent disbursements of funds to even operate. Missing a single payment could require immediate firings or the discontinuation of entire programs. See ECF Nos. 24-4 ¶¶ 4, 6; 24-5 ¶ 13. When an agency suddenly changes course, it must recognize “that longstanding policies may have engendered serious reliance interests that must be taken into account.” Dep’t of Homeland Sec. v. Regents of the Univ. of Cal., 591 U.S. 1, 30 (2020) (internal quotation marks omitted) (quoting Encino Motorcars, LLC v. Navarro, 579 U.S. 211, 221-22 (2016)). Defendants entirely failed to do so.

In the simplest terms, the freeze was ill-conceived from the beginning. Defendants either wanted to pause up to $3 trillion in federal spending practically overnight, or they expected each federal agency to review every single one of its grants, loans, and funds for compliance in less than twenty-four hours. The breadth of that command is almost unfathomable. See ECF No. 30, at 17 (“[I]t is unclear whether twenty-four hours is sufficient time for an agency to independently review a single grant, let alone hundreds of thousands of them.”). Either way, Defendants’ actions were irrational, imprudent, and precipitated a nationwide crisis. Plaintiffs have therefore shown a likelihood of success on their arbitrary and capricious claim.

d. Excess of statutory authority

Plaintiffs’ second claim argues that Defendants dramatically overstepped the bounds of their legal authority in ordering a nationwide funding freeze.12 Agencies “are creatures of statute” and are therefore subject to the limits prescribed by Congress. Nat’l Fed’n of Indep. Bus. v. Dep’t of Lab., Occupational Safety & Health Admin., 595 U.S. 109, 117 (2022) (“OSHA”). In other words, they “‘literally ha[ve] no power to act’ except to the extent Congress [has] authorized.” Marin Audubon Soc’y v. Fed. Aviation Admin., 121 F.4th 902, 912 (D.C. Cir. 2024) (first alteration in original) (quoting Fed. Election Comm’n v. Ted Cruz for Senate, 596 U.S. 289, 301 (2022)). If an agency exceeds that power, the court must set aside its action under the APA. See 5 U.S.C. § 706(2)(C).

OMB’s organic statute is 31 U.S.C. § 503. Within it, Defendants primarily rely on subsections (a)(2) and (a)(5), but neither appears to grant the expansive authority that OMB tried to exercise here. Under subsection (a)(2), OMB may “[p]rovide overall direction and leadership to the executive branch on financial management matters by establishing financial management policies and requirements.” Id. § 503(a)(2). But providing overall direction and establishing financial management policies do not clearly confer the power to halt all finances, full-stop, on a moment’s notice. Indeed, the structure and provisions of Section 503 strongly suggest that OMB occupies an oversight role. Defendants have not pointed to specific authority that allows it to unilaterally pull the plug on nearly all federal monetary flows.

Subsection (a)(5) further indicates that OMB’s role is mainly supervisory, rather than directly active. That subsection permits OMB to “monitor the financial execution of the budget in relation to actual expenditures.” Id. § 503(a)(5). Such language falls well short of actively deciding whether agencies “must temporarily pause” all federal financial assistance. Defendants cannot convincingly argue that “monitor” rises to that level of affirmative control. See Monitor, The Oxford English Dictionary (2d ed. 1989) (defining “monitor” as “to observe, supervise, or keep under review”).

When an agency seeks to “exercise powers of vast economic and political significance,” the “sheer scope of [an agency]’s claimed authority” can trigger heightened judicial scrutiny. Ala. Ass’n of Realtors v. Dep’t of Health & Hum. Servs., 594 U.S. 758, 764 (2021) (per curiam) (internal quotation marks omitted) (quoting Util. Air Regul. Grp. v. EPA, 573 U.S. 302, 324 (2014)). In such situations, the court “expect[s] Congress to speak clearly” when conferring such authority. OSHA, 595 U.S. at 117 (quoting Ala. Ass’n of Realtors, 594 U.S. at 764). The Supreme Court has referred to this principle as the “major questions doctrine.” Id. at 122 (Gorsuch, J., concurring). Based on the cases in which the Supreme Court has invoked the doctrine, this case easily qualifies. See Ala. Ass’n of Realtors, 594 U.S. at 764 (applying the doctrine where the Centers for Disease Control and Prevention implemented a nationwide eviction moratorium affecting up to 17 million tenants); OSHA, 595 U.S. at 117-18 (applying the doctrine where OSHA required all federal employees to obtain COVID-19 vaccinations).

“When an agency claims to discover in a long-extant statute an unheralded power to regulate ‘a significant portion of the American economy,’” the court “typically greet[s] its announcement with a measure of skepticism.” Util. Air Regul. Auth. Grp., 573 U.S. at 324 (quoting FDA v. Brown & Williamson Tobacco Corp., 529 U.S. 120, 159 (2000)). Here, Defendants attempted to freeze as much as $3 trillion dollars—the sum total of “all activities related to [the] obligation or disbursement of all Federal financial assistance.” OMB Pause Memorandum, at 2. That is “no everyday exercise of federal power.” OSHA, 595 U.S. at 117 (internal quotation marks omitted) (quoting In re MCP No. 165, Occupational Safety & Health Admin., 20 F.4th 264, 272 (6th Cir. 2021) (Sutton, C.J., dissenting)).

The scope of power OMB seeks to claim is “breathtaking,” and its ramifications are massive. Ala. Ass’n of Realtors, 594 U.S. at 764. Because there is no clear statutory hook for this broad assertion of power, Plaintiffs are likely to succeed on the merits of this claim.

e. First Amendment

Plaintiffs’ third claim alleges that Defendants are “threaten[ing] [the] continued receipt of federal financial assistance based explicitly on [the recipients’] exercise of their core First Amendment rights of speech and association.” ECF No. 40, at 26. Defendants counter that the government may “selectively fund a program to encourage certain activities” without simultaneously “funding an alternative program [that] deal[s] with the problem in another way.” ECF No. 47, at 34 (quoting Rust v. Sullivan, 500 U.S. 173, 193 (1991)). Defendants are correct that the government “is not required to subsidize First Amendment rights,” Leathers v. Medlock, 499 U.S. 439, 450 (1991), or “assist others in funding the expression of particular ideas,” Ysursa v. Pocatello Educ. Ass’n, 555 U.S. 353, 358 (2009). And refusing to pay for certain speech generally does not inflict a First Amendment harm. See Rust, 500 U.S. at 193.

What is less clear, however, is whether the government may deliberately withhold funds that have already been earmarked for certain recipients based exclusively on the recipient’s viewpoints. Rust and similar decisions by the Supreme Court “are grounded in the notion that the ‘Due Process Clauses generally confer no affirmative right to governmental aid.’” J.D. v. Azar, 925 F.3d 1291, 1327 (D.C. Cir. 2019) (quoting Webster v. Reprod. Health Servs., 492 U.S. 490, 507 (1989)). But that calculus could change if individuals or organizations have already been awarded certain funds and grants—as is the case with Plaintiffs’ members here. If Defendants were to unfreeze promised funds only to organizations expressing one view, but not to organizations expressing the opposite view, that could raise First Amendment concerns.

Additionally, the Supreme Court has held that the government “may not deny a benefit to a person on a basis that infringes his constitutionally protected . . . freedom of speech[,] even if he has no entitlement to that benefit.” Agency for Int’l Dev. v. All. for Open Soc’y Int’l, Inc., 570 U.S. 205, 214 (2013) (“USAID”) (emphasis added) (quoting Rumsfeld v. F. for Acad. & Institutional Rights, 547 U.S. 47, 59 (2006)). It has also made clear that the government cannot “leverage funding to regulate speech outside the contours of the [funding] program itself.” Id. at 214-15 (emphasis added). In other words, when the government exerts First Amendment pressures that have nothing to do with the actual financial assistance program, that can be a constitutional violation. Plaintiffs rely on that principle here. Defendants respond by arguing that the OMB Pause Memorandum is solely framed around “focusing taxpayer dollars” and “[t]he use of federal resources,” rather than governing speech beyond the scope of federal financial assistance. ECF No. 47, at 34-35 (alteration in original) (citing OMB Pause Memorandum, at 1).

While the answer is not obvious at this early stage, Plaintiffs have shown some likelihood of success on their First Amendment claim. The Supreme Court has remarked that the line between proper subsidization and improper coercion “is hardly clear . . . because the definition of a particular program can always be manipulated to subsume the challenged condition.” USAID, 570 U.S. at 215. That said, the government “cannot recast a condition on funding as a mere definition of its program in every case, lest the First Amendment be reduced to a simple semantic exercise.” Id. (quoting Legal Servs. Corp. v. Velazquez, 531 U.S. 533, 547 (2001)). The OMB Pause Memorandum made several policy statements that are hostile to concepts like “Marxist equity,” “transgenderism,” and “woke gender ideology.” OMB Memorandum, at 2. It also instructed federal agencies to pause all disbursements that could be connected to these ill-defined categories. Id. There is no indication that expressing viewpoints on these issues (or being associated with them at all) is in any way tied to the “contours of the [funding] program[s] [themselves].” USAID, 570 U.S. at 214-15.

The government “may not ‘aim at the suppression of dangerous ideas’” or “manipulate[]” a subsidy “to have a coercive effect.” Nat’l Endowment for the Arts v. Finley, 524 U.S. 569, 587 (1998) (brackets omitted) (first quoting Regan v. Tax’n Without Representation of Wash., 461 U.S. 540, 550 (1983), then quoting Ark. Writers’ Project, Inc. v. Ragland, 481 U.S. 221, 237 (1987) (Scalia, J., dissenting)). By appearing to target specific recipients because they associate with certain ideas, Defendants may be crossing a constitutional line.

2. Irreparable Harm

While irreparable injury is “a high standard,” England, 454 F.3d at 297, the court’s analysis of this factor remains unchanged from the TRO stage. Defendants have not introduced arguments or evidence sufficient to undercut Plaintiffs’ strong showing of irreparable harm.

To qualify for injunctive relief, the alleged injury “must be both certain and great,” “actual and not theoretical,” and “of such imminence that there is a ‘clear and present’ need for equitable relief.” Id. (quoting Wis. Gas Co. v. Fed. Energy Regul. Comm’n, 758 F.2d 669, 674 (D.C. Cir. 1985) (per curiam)). It must also “be beyond remediation,” meaning that “[t]he possibility [of] adequate compensatory or other corrective relief . . . at a later date . . . weighs heavily against a claim of irreparable harm.” Id. at 297-98 (quoting Wis. Gas Co., 758 F.2d at 674).

Here, Plaintiffs have produced significant evidence that a pause on federal funding will “threaten[] the very existence of [their members’] business.” Wis. Gas Co., 758 F.2d at 674. A freeze will not simply inconvenience them, it will devastate them. The court recounts its findings from before, which still hold true today:

If the freeze were to remain in effect [or recur], Plaintiffs’ members will suffer “existential injuries” and some programs may “simply disappear.” ECF No. 5-1, at 12. Their workers may be unable to pay for housing or food. ECF No. 24-4 ¶ 7 (“A lot of our staff live paycheck to paycheck, and if they can’t get paid, then they are unable to pay rent or buy groceries.”). Some have already been forced to “shutter [their] programs” just to make payroll. ECF No. 24-7 ¶¶ 20-21. And patients or customers that rely on their services may be denied care when it is most needed. ECF Nos. 24-4 ¶ 16; 24-5 ¶ 21. For some, these are harms for which “there can be no do over and no redress.” Newby, 838 F.3d at 9 (quoting League of Women Voters of N.C. v. North Carolina, 769 F.3d 224, 247 (4th Cir. 2014)); see ECF No. 24-4 ¶ 7 (“[I]f my Health Center loses physicians, dentist, or nurse practitioners, then it will be virtually impossible to recruit replacements to a rural Health System that is suddenly an unreliable source of income.”).


ECF No. 30, at 27.

While funds have resumed flowing to some recipients, that does not erase the imminence or irreparability of what another pause would entail. As at least one declarant explained, the resumption of funding “came in under the wire: had it been one day later, we would not have been able to make payroll on Friday, February 7.” ECF No. 40-3 ¶ 4. As discussed previously, all of these organizations rely on continued funding in order to keep their doors open.

The fact that organizations have been able to draw down funds in the immediate aftermath of the court’s TRO means nothing if the spigot is shut off again. The injunctive relief that Defendants fought so hard to deny is the only thing in this case holding potentially catastrophic harm at bay.13 The court’s previous order may have bought Plaintiffs a few additional weeks of funding, but they remain just as vulnerable as they were in the first week of February. A single disbursement does not protect a recipient when the next disbursement is equally as vital. Plaintiffs have easily shown irreparable harm.

3. Balance of the Equities and the Public Interest

As is the case with irreparable harm, the balance of the equities and the public interest continue to weigh heavily in favor of injunctive relief. “Plaintiffs paint[ed] a stark picture of nationwide panic in the wake of the funding freeze.” ECF No. 30, at 28. Nonprofits and organizations across the country were left adrift as they scrambled to make sense of the memorandum and its effects. See ECF Nos. 24-4, 24-5, 24-6, 24-7, 24-8, 24-9, 24-10, 24-11. Entire funding portals were taken offline with no rhyme or reason, generating significant confusion and fear. See ECF Nos. 24-8 ¶¶ 8-9; 24-6 ¶ 15; 24-7 ¶ 13; 24-8 ¶ 9. Many organizations had to resort to desperate measures just to stay operational. The pause placed critical programs for children, the elderly, and everyone in between in serious jeopardy. Because the public’s interest in not having trillions of dollars arbitrarily frozen cannot be overstated, Plaintiffs have more than met their burden here.

4. Bond

Federal Rule of Civil Procedure 65(c) states that the court may issue a TRO or preliminary injunction “only if the movant gives security in an amount that the court considers proper to pay the costs and damages sustained by any party found to have been wrongfully enjoined or restrained.” Here, Defendants ask the court to require Plaintiffs to “post a bond commensurate with the scope of the relief ordered.” ECF No. 47, at 44-45. The court declines. Rule 65(c) “has been read to vest broad discretion in the district court to determine the appropriate amount of an injunction bond,” DSE, Inc. v. United States, 169 F.3d 21, 33 (D.C. Cir. 1999), “including the discretion to require no bond at all,” P.J.E.S. ex rel. Escobar Francisco v. Wolf, 502 F. Supp. 3d 492, 520 (D.D.C. 2020) (quoting Simms v. District of Columbia, 872 F. Supp. 2d 90, 107 (D.D.C. 2012)). A bond “is not necessary where requiring [one] would have the effect of denying the plaintiffs their right to judicial review of administrative action.” Nat. Res. Def. Council, Inc. v. Morton, 337 F. Supp. 167, 168 (D.D.C. 1971) (collecting cases); cf. Nat’l Ass’n of Diversity Officers in Higher Educ. v. Trump, No. 25-CV-333, 2025 WL 573764, at *29 (D. Md. Feb. 21, 2025) (setting a nominal bond of zero dollars because granting the defendants’ request “would essentially forestall [the] [p]laintiffs’ access to judicial review”). In a case where the government is alleged to have unlawfully withheld trillions of dollars of previously committed funds to countless recipients, it would defy logic—and contravene the very basis of this opinion—to hold Plaintiffs hostage for the resulting harm. That is especially so when Defendants—OMB and its director—will personally face no monetary injury from the injunction.14

III. CONCLUSION

For the foregoing reasons, the court will enter a preliminary injunction. A separate order will issue.

LOREN L. ALIKHAN
United States District Judge

Date: February 25, 2025

_______________

Notes:

1 Although Plaintiffs originally named then-Acting Director of the Office of Management and Budget Matthew Vaeth as a defendant, Russell Vought—who was confirmed by the Senate on February 6, 2025—“is automatically substituted as a party” in Mr. Vaeth’s place pursuant to Federal Rule of Civil Procedure 25(d).

2 The memorandum included a footnote stating: “Nothing in this memo should be construed to impact Medicare or Social Security benefits.” OMB Pause Memorandum, at 1 n.2.

3 The court issued the administrative stay from the bench shortly before the “temporary pause” of federal funding was set to take effect at 5:00 p.m. Tr. of Emergency Hr’g, at 23:21-24:5, Nat’l Council of Nonprofits, No. 25-CV-239 (D.D.C. Jan. 28, 2025).

4 The same day, Beatrice Adams moved to intervene on behalf of herself and all others similarly situated. ECF No. 19. She sought to dissolve the court’s then-active administrative stay, arguing that child-welfare funding was being used to “facilitate the separation of children from loving homes.” Id. at 3-4. Both parties oppose Ms. Adams’s intervention. ECF Nos. 41, 42. The court will deny Ms. Adams’s motion. To the extent she only seeks to challenge the administrative stay, Ms. Adams’s motion to intervene is now moot. In any event, Ms. Adams’s claims are too factually and legally attenuated from those alleged in Plaintiffs’ complaint, and Defendants are “already adequately representing the Government’s interests in ensuring that all federal funding is administered appropriately.” ECF No. 42, at 1.

5 While the court did not fully address Plaintiffs’ other two claims (that Defendants’ actions were in excess of statutory authority and violated the First Amendment), it noted that they had shown at least some likelihood of success on both. ECF No. 30, at 20 n.6.

6 In the interim, on February 14, the American Center for Law and Justice filed an amicus brief in support of Defendants. ECF No. 46.

7 Amicus American Center for Law and Justice echoes Defendants’ mootness argument, claiming that “none of [Plaintiffs’] desired terms of the Prayer for Relief can be implemented [because] there is no OMB Memo that can be enjoined, restrained, or vacated.” ECF No. 48, at 3. The court has already rejected this argument. To the extent that Plaintiffs’ prayer for relief is limited only to the memorandum, they have shown that the rescission had no real effect on Defendants’ actions. For days after the memorandum purportedly ceased to exist, agencies continued to withhold funds pursuant to its authority. See ECF No. 24-1, at 7. If Amicus were correct, a government agency could order illegal activity, retract that order in name only while continuing to implement its substance, and escape legal liability. The court refuses to ratify such behavior. Amicus goes on to argue that “Plaintiffs cannot use a Complaint directed against the OMB Memo as a basis for obtaining relief against all pauses of whatever basis,” ECF No. 48, at 5, but this misconstrues the requested injunctive relief. Plaintiffs made clear at the preliminary injunction hearing that they only seek to prevent Defendants from ordering or implementing unilateral, blanket pauses across the entire federal funding apparatus. See Tr. of Prelim. Inj. Hr’g, at 55:15-18, Nat’l Council of Nonprofits, No. 25-CV-239 (Feb. 20, 2025) (proposing an order that would enjoin a “unilateral[] . . . freeze on the payment of open awards on a non-individualized basis”). In other words, Plaintiffs wish to use a complaint directed against an agency-ordered blanket freeze to obtain relief against that precise action.

8 Defendants acknowledge, however, that Plaintiffs’ statutory claim—whether OMB has the power and authority to order “a government-wide halt on trillions of dollars in grants, loans, and other forms of financial assistance”—does not raise ripeness concerns. ECF No. 47, at 20 n.2.

9 Indeed, some agencies froze funding portals and resources even before the OMB Guidance Document was issued. Those agencies were necessarily operating pursuant to the original OMB Pause Memorandum, not the subsequent guidance. See, e.g., ECF Nos. 24-4 ¶ 8 (unable to access funding portal during the day on January 28, before Plaintiffs’ complaint was filed around noon); 24-7 ¶ 13 (same); 24-8 ¶ 9 (unable to access fund portal as early as January 27).

10 Both Defendants and Amicus argue that “[t]emporary funding pauses are not an unusual exercise of executive authority.” ECF No. 48, at 6; see ECF No. 47, at 26-28, 30-31. For support, they rely on President Biden’s pause of funding to the southern border wall, Proclamation No. 10,142, Termination of Emergency With Respect to the Southern Border of the United States and Redirection of Funds Diverted to Border Wall Construction, 86 Fed. Reg. 7225 (Jan. 20, 2021), and President Obama’s thirty-day delay of Recovery Act funds, Mem. No. E9-6754, Ensuring Responsible Spending of Recovery Act Funds, 74 Fed. Reg. 12531 (Mar. 20, 2009). Without passing judgment on the merits of any hypothetical challenges to those executive decrees, the court is unpersuaded that targeted pauses of funding for specific projects through an executive order are at all comparable OMB’s nationwide suspension of all federal financial assistance. Again, the court disagrees with Defendants’ and Amicus’s characterization of the pause in this case as “targeted” and “discrete” when the language of the memorandum applied to the “disbursement of all Federal funds under all open awards.” OMB Pause Memorandum, at 2.

11 Defendants repeatedly reference the memorandum’s limitation that agencies only act “to the extent permissible under applicable law,” OMB Pause Memorandum, at 2, but this does not save them. First, the incantation of magic language cannot justify otherwise-illegal action. Plaintiffs’ entire complaint alleges that Defendants’ instruction was unlawful to begin with. Second, even assuming that this language applies does not change the arbitrary-and-capricious analysis. Just because an agency can do something does not make it rational to do so.

12 As was the case at the TRO stage, a plaintiff who brings multiple claims only needs to show a likelihood of success on one of them to obtain injunctive relief. See Media Matters for Am. v. Paxton, 732 F. Supp. 3d 1, 27 (D.D.C.), appeal filed, No. 24-7059 (D.C. Cir. 2024). In the interest of being thorough, the court will address each of Plaintiffs’ claims here.

13 The court reiterates that the District of Rhode Island’s TRO does not lessen the severity of the potential irreparable harm in this case. This court has no control over the District of Rhode Island’s decisions and a TRO in that case does “not block this court from entering a TRO of its own.” ECF No. 30, at 28 n.9; see Whitman-Walker Clinic, Inc. v. U.S. Dep’t of Health & Hum. Servs., 485 F. Supp. 3d 1, 60 (D.D.C. 2020) (“[C]ourts routinely grant follow-on injunctions against the Government, even in instances when an earlier nationwide injunction has already provided plaintiffs in the later action with their desired relief.”) (collecting cases).

14 The court also denies Defendants’ request for an administrative stay pending appeal as premature. Id. at 45. If Defendants, after reviewing this opinion and its accompanying order, believe that a stay pending appeal is warranted, they may make a request consistent with Federal Rule of Appellate Procedure 8.
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Re: Anti-Anti-Nazi Barbarian Hordes are Knocking Down the Ga

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Senator Cory Booker BREAKS RECORD in HISTORIC Speech
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Part 1 of 2

https://www.courtlistener.com/docket/69 ... 26-v-musk/
Does 1-26 v. Musk (8:25-cv-00462)
District Court, D. Maryland
Assigned To: Theodore David Chuang

Case Summary: Trump’s executive order renames the U.S. Digital Service as the U.S. DOGE Service (Department of Government Efficiency) and reestablishes the office under the Executive Office of the President. Twenty-six current and former USAID employees or contractors filed a lawsuit claiming that Elon Musk’s constitutional authority to exercise significant government powers as the head of DOGE without Senate confirmation violates the Appointments Clause. The complaint alleges that Musk and the DOGE staff are exercising “significant authority” by controlling agency operations, making personnel decisions, and directing federal spending, all powers the plaintiffs claim can be wielded only by properly appointed officers of the United States. The lawsuit argues that Musk is functioning as a principal officer while evading the constitutional requirement for Senate confirmation. The plaintiffs also claim that Musk’s actions would be unconstitutional even if he were considered merely an inferior officer, as Congress has not authorized the President to directly appoint anyone to his position. The plaintiffs also argue that DOGE’s structure violates separation of powers by creating a “shadow chain of command” that undermines Congress’s power to create agencies and their authorities through statute, confirm appointed officers, and conduct oversight. The suit asks the court to declare Musk and DOGE to be acting unlawfully, enjoin Musk and DOGE from exercising government authority unless appointed by proper process, and set aside their actions taken to date.
Update 1: On Feb. 18, Plaintiffs filed a motion for a preliminary injunction.
Update 2: On Feb. 24, Defendants filed a motion in response to the request for a preliminary injunction; to which the Plaintiffs replied on Feb. 26.
Update 3: On Mar. 18, the Court granted in part and denied in part the Plaintiffs’ motion for a preliminary injunction, finding that the Plaintiffs demonstrated a likelihood of success on the merits and risk of irreparable harm. The Court ordered DOGE to reinstate access to email, payments, security notifications, and other electronic systems. The Court did not enjoin Defendants from carrying out mass personnel and contract terminations but did enjoin them from taking further action in a number of categories such as additional personnel and contract terminations and closures of offices.
Update 4: On Mar. 19, Defendants filed a motion for clarification or modification of the preliminary injunction order issued by the Court on Mar. 18, claiming Jeremy Lewin should not be bound by the preliminary injunction because he is no longer the DOGE Team Lead at USAID.
Update 5: On Mar. 20, the court denied Defendant’s motion for clarification or modification of the preliminary injunction order, confirming Lewin is bound by the preliminary injunction.
Update 6: On Mar. 21, Defendants appealed the Court’s preliminary injunction and denial of Defendants’ motion for clarification or modification to the Fourth Circuit.
Update 7: On Mar. 25, the Court ordered that the district court’s preliminary injunction be stayed until the close of business on Thurs., Mar. 27.
Update 8: On Mar. 28, the Fourth Circuit granted the Defendants’ motion for a stay pending appeal.

https://storage.courtlistener.com/recap ... 8.18.0.pdf

https://storage.courtlistener.com/recap ... 8.18.0.pdf

FILED: March 28, 2025

UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT

No. 25-1273
(8:25-cv-00462-TDC)

J. DOES 1-26,

Plaintiff – Appellee,

v.

ELON MUSK, in his official capacity; UNITED STATES DOGE SERVICE; DEPARTMENT OF GOVERNMENT EFFICIENCY,

Defendants – Appellants.

O R D E R

Upon consideration of Defendants’ Emergency Motion for Stay Pending Appeal, the Court orders that the district court’s preliminary injunction dated March 18, 2025, as clarified by its order dated March 20, 2025, be stayed and hereby is stayed pending the resolution of this appeal.

Entered at the direction of Judge Quattlebaum with the concurrence of Judge Niemeyer. Judge Gregory filed a separate opinion concurring in the result.

For the Court

/s/ Nwamaka Anowi, Clerk

QUATTLEBAUM, Circuit Judge, with whom NIEMEYER, Circuit Judge concurred:

Elon Musk, in his official capacity, the United States DOGE Service and the Department of Government Efficiency move to stay the district court’s preliminary injunction pending their appeal. Finding that they have made a strong showing that they are likely to succeed on the merits of the appeal, that they will be irreparably injured absent the stay, that plaintiffs will not be injured because of the stay and that the stay favors the public interest, we grant their motion.

I.

This matter involves the United States Agency for International Development (“USAID”) and President Donald J. Trump’s Executive Order establishing the Department of Government Efficiency (“DOGE”). Exec. Order No. 14,158, 90 Fed. Reg. 8441 (Jan. 29, 2025). Twenty-six unidentified current and former employees or contractors of USAID sued defendants claiming they unlawfully cancelled government contracts, placed USAID personnel on administrative leave, reduced the force of USAID employees and contractors, closed the USAID headquarters and took down the USAID website. Plaintiffs claim those actions violated the Constitution’s Appointments Clause because Musk acted as the Administrator of DOGE without being properly appointed for that position. Additionally, plaintiffs claim that defendants’ actions in dismantling USAID infringe upon Congress’ responsibilities and, therefore, run afoul of separation of powers principles. And for those alleged wrongs, they seek a judicial declaration that defendants, “as currently operating,” are violating the Constitution, that their actions are unlawful and should be set aside and that defendants should be enjoined from “performing their significant and wide-ranging duties unless and until Musk is properly appointed.” ECF No. 14, ¶82.

Defendants disagree, insisting Musk is not an Officer of the United States in his role. Instead, they argue he is a Senior Advisor to the President who may have influence on decisions regarding USAID but does not have the required significant authority to carry out the actions complained of. They contend that Musk is not the actual or effective Administrator of DOGE, pointing out that the President designated Amy Gleason for that position. What’s more, defendants assert the actions complained of at USAID were carried out by duly appointed Officers of the United States—more specifically, that the President designated Secretary of State Marco Rubio as USAID’s Acting Administrator, who then designated Peter Marocco as Deputy Administrator. Defendants add that USAID subsequently, and in accordance with the Executive Order, established an internal DOGE Team led by Jeremy Lewin. And defendants argue that all decisions alleged as unconstitutional are within both agency discretion and the President’s inherent Article II authority to direct foreign policy.

Plaintiffs moved for a preliminary injunction, and the district court granted the motion, finding that defendants’ conduct likely violated the Constitution and harmed plaintiffs and that the injunction was in the public interest. Does 1–26 v. Musk, --- F. Supp. 3d ---, 2025 WL 840574, at *32 (D. Md. Mar. 18, 2025). The district court ordered that defendants1 (1) reinstate access to various computer and electronic systems of current USAID employees and contractors, whether in active status or on administrative leave; (2) not disclose any confidential information of current USAID employees and contractors, whether in active status or on administrative leave; (3) not take any action relating to the shutdown of USAID; (4) not take any action relating to USAID without authorization from a USAID official; and (5) submit to the court a written agreement indicating USAID will be able to occupy its headquarters in Washington, D.C. in the event plaintiffs prevail in this lawsuit. Id. at *32–33.

Defendants subsequently moved for clarification or modification of that injunction as it pertained to Lewin. While Lewin had led the USAID DOGE Team prior to the injunction, defendants sought clarity about whether the injunction covered Lewin in his current role of chief operating officer at USAID and asked that, if so, Lewin be carved out from the injunction to be able to do his job with USAID. The district court clarified that its injunction did, in fact, include Lewin and declined to grant any modifications. Defendants appealed the district court’s preliminary injunction and its denial of their motion for clarification or modification. They also filed an emergency motion for us to stay the injunction pending the appeal.

II.

Under the well-established standard for granting a stay pending appeal, we consider four factors:

(1) whether the stay applicant has made a strong showing that he is likely to succeed on the merits;

(2) whether the applicant will be irreparably injured absent a stay;

(3) whether issuance of the stay will substantially injure the other parties interested in the proceeding; and

(4) where the public interest lies.

Nken v. Holder, 556 U.S. 418, 434 (2009) (quoting Hilton v. Braunskill, 481 U.S. 770, 776 (1987). Those factors, applied to this record, favor granting a stay of the preliminary injunction pending appeal. Thus, for the reasons described below, we grant defendants’ motion.

A. Likelihood of Success on the Merits

While Nken governs this motion, our consideration of defendants’ likelihood of success on the merits here requires defendants to show that the district court erred in its assessment of plaintiffs’ motion for preliminary injunctive relief under Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008). In essence, “[t]here is substantial overlap between [the Nken factors] and the factors governing preliminary injunctions, . . . not because the two are one and the same, but because similar concerns arise whenever a court order may allow or disallow anticipated action before the legality of that action has been conclusively determined.” Nken, 556 U.S. at 434 (citation omitted).

To start, “preliminary injunctions are extraordinary remedies involving the exercise of very far-reaching power to be granted only sparingly and in limited circumstances . . . .” Direx Israel, Ltd. v. Breakthrough Med. Corp., 952 F.2d 802, 816 (4th Cir. 1991) (internal quotation marks omitted). Granting this sort of relief, when the harm is admittedly not present or immediate, and is conditioned on possible future events, contradicts our rule that a plaintiff seeking preliminary relief must show a present threat of irreparable harm. See id. A plaintiff seeking a preliminary injunction “must establish that he is likely to succeed on the merits, that he is likely to suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in his favor, and that an injunction is in the public interest.” Winter, 555 U.S. at 20. We turn now to the district court’s findings as to the Winter factors.

1.

First, defendants have made a strong showing that the district court erred in finding plaintiffs were likely to succeed on the merits of both their Appointments Clause claim and their separation of powers claim. The ultimate questions in those two claims are who carried out the disputed actions at USAID and did those actions violate the Constitution.

The district court found that defendants established that most of the actions about which plaintiffs complain were approved or ratified by Rubio, Marocco and other USAID officials. Does 1–26, 2025 WL 840574, at *13. And for those reasons, the district court conceded that the terminations of contracts, the administrative leave decisions and the reductions in force were either approved or ratified by USAID officials. Id. (finding “[p]laintiffs have not provided specific evidence refuting [d]efendants’ documentation,” and “that it is, at a minimum, more likely than not that USAID officials either took or ratified the relevant personnel and contract actions”). Thus, as the district court acknowledged, those actions provide no basis for the injunction in connection with plaintiffs’ Appointments Clause claim because those individuals possessed the requisite authority.

The district court concluded, however, that defendants produced no specific evidence showing USAID officials approved or ratified the decisions to move USAID out of its previous headquarters and to take down the USAID website. Id. Therefore, the district court granted the injunction based on those two actions and a finding that as to plaintiffs’ separation of powers claim, defendants, “as well as other government officials, have acted swiftly to shut down, dismantle, and effectively eliminate USAID as an independent agency.” Id. at 18. That conclusion is dubious.

The only evidence cited by plaintiffs in support of their motion, which was subsequently relied on by the district court, were social media posts and news reports. To be sure, Musk claimed involvement in the USAID decisions in those posts and reports. But that is not the point because no one disputes his involvement. The question is whether Musk both directed those decisions and did so without the approval or ratification of USAID officials. And no record evidence shows that he did. In contrast, defendants put forth evidence that in all pertinent actions, Musk acted as a Senior Advisor to the President and not as the Administrator of DOGE, and that all decisions pertaining to USAID were either made or approved by those so authorized. See ECF No. 28-2. Moreover, the relocation of United States Customs and Border Protection into USAID’s former headquarters and removal of USAID’s website occurred after Rubio and Marocco had assumed their roles at USAID. Finally, the news articles and social media posts detailing Musk’s involvement do not indicate Rubio and Marocco were not part of those two decisions.2

And as to Musk, the evidence before us creates a strong likelihood that he functioned as an advisor to the President, carrying out the President’s policies of shrinking government and reducing spending, not as an Officer who required constitutional appointment. The current evidence in the record indicates that Musk’s actions did not involve the exercise of authority of an office granted by law but rather the implementation of Executive policies. In order to be an Officer, he must (1) be “exercising significant authority pursuant to the laws of the United States” and (2) be “occupying a continuing position established by law.” Lucia v. SEC, 585 U.S. 237, 245 (2018) (cleaned up). Based on the current record, it appears that Musk’s role satisfies neither criterion.

Further, regardless of whether the alleged actions—authorized, ratified or not—could form the basis of a separation of powers claim that the Executive branch is dismantling USAID in contravention of the Legislative branch’s power, plaintiffs have failed, in part, to name the unconstitutional actors as defendants. The district court identified USAID as authorizing and ratifying all actions complained of except closing the prior USAID headquarters and taking down its website. Yet, neither the Executive nor USAID is named here. Confined to the two allegedly unlawful actions identified by the district court, there is no strong likelihood of success on the merits of a separation of powers claim against a defendant who the district court found to be acting without authority and who the government claims is not an Officer of the United States.3

While defendants’ role and actions related to USAID are not conventional, unconventional does not necessarily equal unconstitutional. And none of this is to say that plaintiffs will not be able to develop evidence of unconstitutional conduct as the case progresses. Time will tell. Our holding is merely that, at this time, the record does not support the district court’s finding of a likelihood of constitutional violations.

2.

Even apart from the evidentiary issues, defendants have shown that the district court erroneously concluded that plaintiffs showed irreparable harm under Winter. To start, the court correctly noted that these alleged constitutional violations alone, even if established, do not create irreparable harm to these plaintiffs. See Does 1–26, 2025 WL 840574, at *26. Instead, individualized irreparable harm is required. Id. The district court found irreparable harm in three ways.

One, it found that John Doe 22 was an overseas USAID employee in a high-risk location on administrative leave whose electricity, cell phone and internet bills cannot be paid because of USAID’s payment system being shut down. Id. at *27. According to the court, this plaintiff faced a physical security risk that amounted to irreparable harm. Id. But as the court acknowledged, none of the services John Doe 22 complained about have been discontinued, and defendants introduced evidence representing that “overseas employees ‘will retain access to Agency systems and to diplomatic and other resources’ until they return to the United States.” Id.

Two, the district court found that another plaintiff, John Doe 12, had heard remarks accusing USAID workers of being corrupt. Id. at *28. And it noted that John Doe 9 said “Musk’s derogatory statements about USAID are available on media outlets in [the Middle East] region and ‘have a direct negative impact on the perception of USAID where [he] work[s].’” Id. Again, to the district court, this showed irreparable harm. Id.

Three, the district court found plaintiffs’ fear that personal, confidential and sensitive information could be released created irreparable harm. Id. But other than the district court’s concern over defendants’ alleged lack of care regarding security clearances and a lack of “assurances” from DOGE that it will comply with protocols for personal information, the record contains no evidence of any such disclosure. Id. at *28–29.

None of this evidence establishes the irreparable harm required to issue an injunction. Our law is clear. The “frequently reiterated standard requires plaintiffs seeking preliminary relief to demonstrate that irreparable injury is likely in the absence of an injunction.” Winter, 555 U.S. at 22 (emphasis in original). “To establish irreparable harm, the movant must make a ‘clear showing’ that it will suffer harm that is ‘neither remote nor speculative, but actual and imminent.’” Mountain Valley Pipeline, LLC v. 6.56 Acres of Land, Owned by Sandra Townes Powell, 915 F.3d 197, 216 (4th Cir. 2019) (quoting Direx, 952 F.2d at 812).

Turning to plaintiffs here, the district court found irreparable harm based on subjective fear of a lack of physical security, fear of nonpayment of expenses, fear their reputations will be harmed by the negative comments of defendants about USAID employees and contractors and fear that their confidential information might be exposed. But subjective fear that is remote and speculative is insufficient to show the required actual and imminent harm to establish irreparability.

Aside from their fear-based alleged damages, plaintiffs allege emotional distress based largely on loss of employment or contract status. See ECF No.17-1, pp. 19–20 (“J. Doe 19, . . . lost access to their email and all USAID systems . . . and has received no information about their employment status. . . . J. Doe 19 is ‘emotionally and psychologically harmed’ by Defendants’ actions.”) (internal citations omitted). However, they allege no violations of employment law or any breach of contract. Id. And even more significantly, they do not allege facts that show any physical manifestations or medical treatment which is required for almost any emotional distress claim recognizable by law. Id.

Furthermore, to the extent these alleged harms are cognizable damages at all, most can be remedied by money damages. Generally, injuries that can be cured by monetary relief, by law, are not irreparable. See Sampson v. Murray, 415 U.S. 61, 90 (1974) (“[T]he temporary loss of income, ultimately to be recovered, does not usually constitute irreparable injury.”); see also Hughes Network Sys., Inc. v. InterDigital Commc’ns Corp., 17 F.3d 691, 694 (4th Cir. 1994) (“Monetary relief typically may be granted as easily at judgment as at a preliminary injunction hearing, and a party does not normally suffer irreparable harm simply because it has to win a final judgment on the merits to obtain monetary relief.”). In sum, plaintiffs have failed to show any irreparable injury to date as required under our precedent.

3.

Last, for several reasons, defendants have shown the district court erred in concluding that the balance of equities favors issuing an injunction and that the injunction furthers the public interest.

To begin, the mandatory obligations of the district court’s order extend well beyond granting relief to the individual plaintiffs who brought this lawsuit and enjoining the defendants named. Injunctions of this scope are disfavored when, as here, they are unnecessary to address the alleged harms. See Labrador v. Poe ex rel. Poe, 144 S. Ct. 921, 927 (2024) (mem.) (Gorsuch, J. concurring) (stating “universal injunctions circumvent normal judicial processes and ‘tend to force judges into making rushed, high-stakes, low-information decisions’ at all levels”); see also Order Granting Defendants’ Motion for a Stay Pending Appeal, Nat’l Ass’n of Diversity Officers in Higher Educ. v. Donald J. Trump, No. 25-1189 (4th Cir. Mar. 14, 2025), Dckt. No. 29 (granting the government’s request for a stay pending appeal of a nationwide injunction banning the government’s enforcement of two Executive Orders pertaining to diversity, equity and inclusion).

Also, the district court failed to limit relief to the irreparable harms it found—fear of physical security, fear of nonpayment of expenses, fear of reputational harm and fear of disclosure of confidential information. For example, the district court’s injunction requires defendants to submit to the district court a written agreement indicating USAID will be able to occupy its headquarters in Washington, D.C. in the event plaintiffs prevail. Does 1–26, 2025 WL 840574, at *33. This part of the court’s order does little to allay plaintiffs’ fear-based claims. In addition, while the rest of the injunction may address some of the fear-based harms John Doe 22 complains of regarding physical security and payment, it fails to provide any relief for the alleged reputational harms of John Doe 9 and John Doe 12.

Next, the mandatory obligations of the injunction are inconsistent with the district court’s express findings regarding authorized actions. The district found that USAID officials approved or ratified the decisions to terminate certain USAID contracts, to place certain USAID employees on administrative leave and to terminate others; yet, the district court’s order requires defendants to reinstate various computer and electronic systems of USAID employees and contractors on administrative leave. If, as the district court explained, the administrative leave and contract termination decisions were not unconstitutional, injunctive relief reinstating terminated access is inappropriate.

Continuing, the injunction order requires vast and detailed actions related to the operation of USAID, an Executive agency. But neither that agency, nor its leaders, nor the Executive branch are named as parties to the lawsuit. Not only that, the district court ordered defendants, who it earlier found to lack constitutional authority to act for USAID, to carry out those remedial actions for the agency. In other words, the district court ordered more of the conduct that it held to be unconstitutional. These inconsistent conclusions cannot support the relief ordered by the court.

For all these reasons, the district court’s order does not properly balance the equities involved in this case. And it follows that it harms, rather than furthers, the public interest.

B. Remaining Nken Factors

Having evaluated defendants’ likelihood of success on the merits, we turn to the remaining Nken factors. But we need not spend much time here because, as stated earlier, much of the analysis of the underlying preliminary injunction considers these same points.

The next Nken factor considers whether defendants will be irreparably injured absent a stay. Here, the district court’s order prevents defendants from complying with Executive branch instructions because the district court summarily determined that Rubio, Marocco and Lewin are blindly taking instructions from defendants. That means the district court has, based on alleged injuries from a handful of plaintiffs, issued injunctive orders that dictate and restrict a separate branch of government. Unlike the harm alleged by plaintiffs, this harm cannot be remedied by monetary damages. It truly is irreparable.

Turning to whether the issuance of the stay will substantially injure the other parties interested in the proceeding, the analysis of plaintiffs’ harms under Section II.A.2 establishes that the answer is no. Plaintiffs’ alleged harms are not actual or imminent and are certainly not irreparable. Also, nothing in the record shows any injuries plaintiff might be able to establish as the case progresses could not be addressed through the normal litigation process.

Last, as to the public interest, the public certainly has an interest in ensuring the government is acting constitutionally. However, the public also has an interest in judges wielding power only when so authorized. That authorization limits us to deciding cases and controversies, not political disputes. Cases and controversies involve actual injuries to actual parties, not injuries that are speculative and extend beyond the parties in this case. Courts must be wary of stretching to find harm at the preliminary injunction stage when the record does not support it. This is because the normal practice of “methodically developing arguments and evidence,” is necessarily cast aside for what is often and “almost by design a fast and furious business.” Labrador, 144 S. Ct. 921, 927 (2024) (mem.) (Gorsuch, J. concurring) (quoting DHS v. New York, 140 S. Ct. 599, 600 (2020) (mem.) Gorsuch, J. concurring).

In sum, defendants have made the requisite showing under Nken that they have a strong likelihood of success on the merits, that they will be irreparably injured if a stay is not issued, that a stay would not substantially injure plaintiffs and that a stay is in the public interest.

III.

For all these reasons, we grant defendants’ motion to stay the preliminary injunction pending appeal.

_______________

Notes:

1 The individuals enjoined by the preliminary injunction include “Elon Musk, in his official capacity; the United States DOGE Service; the Department of Government Efficiency; and their officers, agents, servants, employees and attorneys,” and “all individuals who at any time from January 20, 2025 through the pendency of [the] Preliminary Injunction have been designated as, or have served in the role as, a DOGE Team Lead or DOGE Team Member pursuant to Executive Order 14,158 for purposes of any activities relating to [USAID], regardless of the personnel status of that individual.” Does 1–26, 2025 WL 840574, at *32.

2 Our concurring colleague claims the Majority “improperly meddles in factual determination properly left to the discretion of the district court,” in violation of our standard of review. Conc. Op. at 17–18 n.1. He is right to emphasis the importance of those standards. We are duty bound to apply them. But we apply our standard of review here in the context of our precedent that instructs that preliminary injunctions should be granted “sparingly and in limited circumstances” because of their implication of “very far-reaching [judicial] power,” Direx Israel, Ltd., 952 F.2d at 816, and that “ambiguity is simply insufficient to support a finding that success on the merits is ‘likely’ rather than merely ‘possible’ . . . .” Di Base v. SPX Corp., 872 F.3d 224, 235 (4th Cir. 2017). In that context, our conclusion is consistent with our standard of review.

3 Our concurring colleague eloquently articulates general principles of separation of powers. At least in the abstract, we agree with many of the principles he recites. But he then applies those principles to parties who are not in this case. Our job is to resolve the actual claims by the actual plaintiffs against the actual defendants. And since we all agree that doing that here requires that the injunction be stayed, we will not opine on what might be a proper claim against parties not before us.

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Re: Anti-Anti-Nazi Barbarian Hordes are Knocking Down the Ga

Postby admin » Wed Apr 02, 2025 2:09 am

Part 2 of 2

GREGORY, Circuit Judge, concurring only in the result:

When Congress first authorized the creation of the USAID in 1961, it spoke of American values and a desire to spread freedom and democracy across the world. See Act for International Development of 1961, Pub. L. No. 87–195, § 102 (1961). For a generation, through times of peace and war, economic prosperity and struggle, Democratic and Republic administrations alike, USAID has remained. But approximately six weeks ago, Defendant Elon Musk and his compatriots “spent the weekend feeding USAID to the wood chipper.” Does 1-26 v. Musk, No. CV 25-0462-TDC, 2025 WL 840574, at *10 (D. Md. Mar. 18, 2025) (citation omitted).

We may never know how many lives will be lost or cut short by the Defendants’ decision to abruptly cancel billions of dollars in congressionally appropriated foreign aid. We may never know the lasting effect of Defendants’ actions on our national aspirations and goals. But those are not the questions before the Court today. The question before us is whether Defendants have satisfied their burden for a stay of the district court’s injunction pending their appeal to this Court. See, e.g., Republican Nat’l Comm. v. N.C. State Bd. of Elections, 120 F.4th 390, 408 (4th Cir. 2024) (Diaz, C.J., concurring) (writing separately to comment on standing despite agreeing on the merits).

Because Plaintiffs failed to include the proper Defendants, I am forced to concur in the Majority’s grant of Defendants’ request for a stay pending appeal. But I write separately to make clear that my concurrence today should not be seen as an endorsement of the Executive’s likely unconstitutional actions in closing USAID, effectively dissolving a “creature[] of statute” that can only be created or destroyed by Congress. See infra § I.; Nat’l Fed’n of Indep. Bus. v. Dep’t of Lab., Occupational Safety & Health Admin., 595 U.S. 109, 117 (2022).

Below, I start by addressing the merits of the case. I first explain why I believe that the Executive’s actions violated the separation of powers. Secondarily, I explain why Defendant Musk acted as an Officer of the United States, in violation of the Appointments Clause, rendering his feeding of USAID to the “wood chipper” constitutionally invalid. But after opining on the merits, I discuss why Plaintiffs have failed to sue the proper Defendants, which has forced me to concur in the Majority’s grant of the stay.

In different circumstances, Plaintiffs very well may have demonstrated a likelihood of success on the merits of their constitutional claims. But like Defendants, I am constrained by the Constitution to go no further than my jurisdiction allows.

I.

I believe the merits of Plaintiffs’ separation of power claim are clear. The Executive branch may not eliminate a congressionally created and funded agency without congressional authorization.1 By doing so here, the Defendants’ actions violated a core tenet of our Constitution.

The Constitution’s great genius is its system of separation of powers. As the Founders recognized, “[i]n framing a government which is to be administered by men over men, the great difficulty lies in this: you must first enable the government to control the governed; and in the next place oblige it to control itself.” The Federalist No. 51 (Alexander Hamilton or James Madison). They understood that if the Constitution put too much power in the hands of one person or one body, the United States risked sliding into tyranny. James Madison acknowledged as much, writing that “[t]he accumulation of all powers legislative, executive and judiciary in the same hands, whether of one, a few or many, and whether hereditary, self appointed, or elective, may justly be pronounced the very definition of tyranny.” The Federalist No. 47 (James Madison).

To address the “great difficulty” of creating a government capable of governing itself, the Founders established a system of separation of powers. The Federalist No. 51 (Alexander Hamilton or James Madison). “The Constitution sought to divide the delegated powers of the new federal government into three defined categories, legislative, executive and judicial, to assure, as nearly as possible, that each Branch of government would confine itself to its assigned responsibility.” INS v. Chadha, 462 U.S. 919, 951 (1983). Article I of the Constitution vests “[a]ll legislative Powers” in Congress, U.S. Const. Art. I, § 1; Article II vests “[t]he executive Power . . . in a President of the United States,” U.S. Const. Art. II, § 1; and Article III vest “the judicial Power” in the federal courts, U.S. Const. Art. III § 1. “Even a cursory examination of the Constitution reveals the influence of . . . [the] thesis that checks and balances were the foundation of a structure of government that would protect liberty.” Bowsher v. Synar, 478 U.S. 714, 722 (1986). “Time and again [the Supreme Court has] . . . reaffirmed the importance in our constitutional scheme of the separation of governmental powers into the three coordinate branches.” Morrison v. Olson, 487 U.S. 654, 693 (1988).

The case before us considers the extent of the President’s power and is governed by the familiar framework set forth in Justice Robert Jackson’s Youngstown concurrence. See Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579 (1952) (Jackson, J. concurring). All members of the Executive branch derive their authority solely from the President, in whom the Constitution vests the Executive power of the United States. See U.S. Const. Art. II, § 1. The President may, of course, delegate his power to Executive branch officials. See, e.g., Seila L. LLC v. Consumer Fin. Prot. Bureau, 591 U.S. 197, 204 (2020). But he may only delegate authority that he possesses. As the Youngstown framework shows, he does not possess the power to shutter USAID or any other congressionally created agency.

The Youngstown framework divides Executive power into three categories. “First, when ‘the President acts pursuant to an express or implied authorization of Congress, his authority is at its maximum, for it includes all that he possesses in his own right plus all that Congress can delegate.’” Zivotofsky ex rel. Zivotofsky v. Kerry, 576 U.S. 1, 10 (2015) (quoting Youngstown, 343 U.S. at 635 (Jackson, J. concurring)). “Second, ‘in absence of either a congressional grant or denial of authority’ there is a ‘zone of twilight in which he and Congress may have concurrent authority,’ and where ‘congressional inertia, indifference or quiescence may’ invite the exercise of executive power.” Id. (quoting Youngstown, 343 U.S. at 637 (Jackson, J. concurring)). “Finally, when ‘the President takes measures incompatible with the expressed or implied will of Congress . . . he can rely only upon his own constitutional powers minus any constitutional powers of Congress over the matter.’” Id. (quoting Youngstown, 343 U.S. at 637 (Jackson, J. concurring)). In the third category, the President’s power is at its “lowest ebb.” Id. (quoting Youngstown, 343 U.S. at 637 (Jackson, J. concurring)).

As these three categories show, “[n]o matter the context, the President’s authority to act necessarily ‘stem[s] either from an act of Congress or from the Constitution itself.’” Trump v. United States, 603 U.S. 593, 607 (2024) (quoting Youngstown, 343 U.S. at 585). This is because we have a President, not a King. Trump v. Vance, 591 U.S. 786, 795 (2020). Our Founders made this choice explicit. Thus, “[i]f the President claims authority to act but in fact exercises mere ‘individual will’ and ‘authority without law,’ the courts may say so.” Trump v. United States, 603 U.S. at 608 (quoting Youngstown, 343 U.S., at 655 (Jackson, J., concurring)). While the President may wield significant power from behind the Resolute Desk, the judiciary must stand just as resolute in ensuring that the President wields his power within the Constitution’s bounds.

Like the district court found, and as I will now explain, I believe that the Executive’s actions here fall in the third and final Youngstown category. And because the President lacks the independent constitutional authority to close a congressionally created and funded agency, I believe that the Executive’s actions violate the separation of powers and are unconstitutional. Simply put, no Executive branch officer—the President, the Secretary of State, and certainly not Defendant Musk—may close USAID or a similar agency without congressional approval.

A.

By shuttering USAID, the Executive acted without Congress’s “express or implied authorization.” Zivotofsky, 576 U.S. at 10 (quoting Youngstown, 343 U.S. at 635 (Jackson, J. concurring)). Lacking Congress’s keys, the Executive cannot claim refuge in the first and most forgiving Youngtown category.

A generation ago, Congress first endowed the President with the authority to create USAID. In 1961, President John F. Kennedy “strongly urge[d]” Congress to enact the legislation establishing USAID. John F. Kennedy, Special Message to the Congress on Foreign Aid (March 22, 1961), The American Presidency Project, https://www.presidency.ucsb.edu/node/236184. Later that year, heeding President Kennedy’s call, Congress did just that. See Act for International Development of 1961, Pub. L. No. 87–195 (1961).

The 87th Congress affirmed that it was American policy “to continue to make available to other free countries and peoples, upon request, assistance of such nature and in such amounts as the United States deems advisable and as may be effectively used by free countries and peoples to help them maintain their freedom.” Id. at § 102. To achieve these aims, Congress authorized the President to create an agency to provide international aid. See generally id. So, like all executive agencies, USAID is a creature of Congress. See Nat’l Fed’n of Indep. Bus., 595 U.S. at 117. Then and only then, “y virtue of the authority vested in [him] by the Foreign Assistance Act of 1961,” President Kennedy established the United States Agency for International Development. Exec. Order 10973, 26 F.R. 10469 (signed Nov. 3, 1961). For over sixty years, USAID has stood as a testament to President Kennedy’s and the 87th Congress’s shared vision.

In 1998, under the Foreign Affairs Reform and Restructuring Act of 1998 (“FARRA”), Pub. L. 105-277, Congress codified USAID in statute. FARRA states:

Unless abolished pursuant to the reorganization plan submitted under section 6601 of this title, and except as provided in section 6562 of this title, there is within the Executive branch of Government the United States Agency for International Development as an entity described in section 104 of title 5, United States Code.


22 U.S.C. § 6563. This remains federal law.

It is true that the statute gave the President the ability to reorganize USAID “pursuant to . . . section 6601,” but that limited authorization has long since expired. Section 6601 allowed the President, “[n]ot later than 60 days after October 21, 1998,” to send Congress a reorganization plan to provide for “the consolidation and streamlining of the Agency [for International Development] and the transfer of certain functions of the Agency to the Department.” 22 U.S.C. § 6601(a). Pursuant to FARRA, President Bill Clinton submitted a reorganization plan on the eve of 1999. See Submitted by President Clinton to the Congress on December 30, 1998, Pursuant to Section 1601 of the Foreign Affairs Reform and Restructuring Act of 1998, as Contained in Public Law 105-277. But President Clinton’s plan did not eliminate USAID. Rather, it reiterated that USAID “will be a separate agency” within the Executive branch. Id. While the statute allowed for the President to modify the reorganization plan, the modification deadline passed more than twenty years ago. 22 U.S.C. § 6601(g)(2). Under FARRA, it is too late for President Trump to dismantle USAID––regardless of whether he acts through Musk, DOGE, Secretary of State Marco Rubio, or any other Executive actor––without first getting the consultation and approval of Congress. It is clear that the Executive cannot “get rid” of USAID without further congressional authorization, contrary to Defendants’ actions. Does 1-26, 2025 WL 840574 at *5–6 (Musk stating: “you’ve just got to basically get rid of the whole thing . . . That is why [USAID has] got to go, it’s beyond repair.”).

Since the limited authorization to modify USAID under FARRA expired, Congress has not granted the President statutory authority to modify, reorganize, or eliminate USAID. That is uncontested. So by shuttering USAID, the President acted without express or implied congressional authorization, in violation of the Constitution.

B.

Not only has the Executive acted without Congress’s blessing, but it has acted in defiance of Congress’s express will. The Executive did not act in response to “congressional inertia, indifference or quiescence,” Youngstown, 343 U.S. at 637 (Jackson, J. concurring), and its actions thus did not fall within Youngstown’s second category.

Congress has consistently voiced its support for USAID. As recently as 2023, several members of the House of Representative introduced a bill to abolish it. See H.R. 5108 (118th Cong.). Instead of passing the measure, Congress increased the funds appropriated to USAID. See Further Consolidated Appropriations Act, 2024, Pub. L. 118–47, Title II (March 23, 2024). Thus, Congress reaffirmed its enduring commitment to USAID and its mission. Cf. United States v. Texas, 599 U.S. 670, 685 (2023) (noting the Congress “possesses an array of tools to analyze and influence [the Executive branch’s] policies” including the appropriation process).

Congress went a step further than merely funding USAID. In the most recent appropriations bill passed in 2024, Congress limited the Executive’s authority to reprogram or allocate funds congressionally appropriated to USAID. Congress stated: “None of the funds made available [to USAID], shall be available for obligation to— . . . (2) suspend or eliminate a program, project, or activity; . . . [or] (4) create, close, reorganize, downsize, or rename bureaus, centers, or offices; . . . unless previously justified to the Committees on Appropriations or such Committees are notified 15 days in advance of such obligation.” Pub. L. 118–47, § 7015(a). Furthermore, Congress stated that

[quote]None of the funds [appropriated to USAID] . . . shall be available for . . . programs, projects, or activities through a reprogramming of funds in excess of $1,000,000 or 10 percent, whichever is less, that—

(1) augments or changes existing programs, projects, or activities;

(2) relocates an existing office or employees;

(3) reduces by 10 percent funding for any existing program, project, or activity, or numbers of personnel by 10 percent as approved by Congress; or

(4) results from any general savings, including savings from a reduction in personnel, which would result in a change in existing programs, projects, or activities as approved by Congress;

unless the Committees on Appropriations are notified 15 days in advance of such reprogramming of funds.

Id. at § 7015(b).

The statute further clarified that “[f]unds appropriated . . . [to] the Department of State, foreign operations, and related programs . . . may not be used to implement a reorganization, redesign, or other plan described . . . [therein] by . . . the United States Agency for International Development . . . without prior consultation by the head of such department, agency, or organization with the appropriate congressional committees.” Id. at § 7063(a).2 Pursuant to the statute, “any such notification submitted to such Committees shall include a detailed justification for any proposed action.” Id. Through these provisions, Congress made its will clear: Before interfering with USAID and its functioning, the President must consult with Congress and comply with the laws enacted by it.

As the district court found as a factual matter, the President did not consult with Congress prior to gutting USAID, as required by Pub. L. 118-47, § 7015 and § 7063. Does 1-26, 2025 WL 840574 at *22–23. While Secretary of State Rubio sent a letter to Congress stating that USAID officials would “begin the process of engaging in a review and potential reorganization of USAID” on February 3, 2025, he only did so after Defendants had already publicly announced the closure of USAID and notified USAID employees of the closure of USAID’s headquarters. Id.; see also id. at *6. As the district court found, “there is no evidence that the congressional committees had the opportunity to weigh in before these key actions were taken and publicly announced.” Id. at *22.

By closing USAID, the Executive acted in flagrant defiance of Congress. This is true whether the Executive acted through the President, a “Senior Advisor,” DOGE, the Secretary of State, USAID’s Interim Director, or any other member of the branch.

C.

Acting without Congressional authority and contravention of Congressional will, the Executive’s power is at “its lowest ebb.” Zivotofsky, 576 U.S. at 10 (quoting Youngstown, 343 U.S. at 637 (Jackson, J. concurring)). To act at this nadir of Executive power, the Executive must demonstrate that it has the inherent constitutional authority to unilaterally shutter a statutorily created and congressionally funded federal agency. Id. It is clear that it does not.

Only Congress can create a federal agency. As the Supreme Court has observed, “[a]dministrative agencies are creatures of statute.” Nat’l Fed’n of Indep. Bus., 595 U.S. at 117. And “Congress has . . . [the] exclusive constitutional authority to make laws necessary and proper to carry out the powers vested by the Constitution ‘in the Government of the United States, or in any Department or Officer thereof.’” Youngstown, 343 U.S. at 588–89; see also U.S. Const. Art. I, § 1. Since the Founding, Congress has exercised its exclusive authority to create federal agencies. See, e.g., An Act for establishing an Executive Department, to be denominated the Department of Foreign Affairs, 1 Stat. 28 (July 27, 1789); An Act for establishing an Executive Department, to be denominated the War Department, 1 Stat. 49 (August 7, 1789). Congress has likewise legislatively reorganized Executive departments. See National Security Act of 1947, Pub. L. No. 80-253 (reorganizing the United States military and intelligence agencies, including creating the Department of Defense). Since the dawn of our Republic, it is Congress, and Congress alone, that has the power to establish and delineate the bounds of an Executive agency.

Just as Congress alone has the power to create an agency, it also has the sole power to abolish an agency. In the past, Congress has abolished agencies it no longer believed were necessary. See, e.g, ICC Termination Act of 1995, Pub. L. No. 104-88 § 101 (abolishing the Interstate Commerce Commission); Homeland Security Act of 2002, Pub. L. 107-296 § 471 (abolishing the Immigration and Naturalization Service). This power must remain solely in Congress’s hands. This is because, as the Supreme Court has long recognized, “the power to destroy may defeat and render useless the power to create.” McCulloch v. Maryland, 17 U.S. 316, 431 (1819). To allow the Executive branch to “destroy” the Legislature’s creations would disrupt the Founders’ careful balance of power. See Olegario v. United States, 629 F.2d 204, 224 (2d Cir. 1980) (“[t]he Constitution’s grant of executive authority does not include the right to nullify legislative acts or ignore statutory directives.”).

The fact that USAID is associated with the exercise of foreign policy does not change this analysis. While it is true that, “in foreign affairs the President has a degree of independent authority to act,” Am. Ins. Ass’n v. Garamendi, 539 U.S. 396, 414 (2003), Congress and the President still share “authority over the Nation’s foreign relationships,” Bank Markazi v. Peterson, 578 U.S. 212, 235 (2016); see also Zschernig v. Miller, 389 U.S. 429, 432 (1968) (“the Constitution entrusts [the field of foreign affairs] to the President and the Congress.”) (emphasis added). The field of foreign policy is not the President’s exclusive domain, nor does acting in that field give him a carte blanche to ignore congressional will. See, e.g., Youngstown, 343 U.S. at 646 (Jackson, J. concurring) (“[n]o penance would ever expiate the sin against free government of holding that a President can escape control of executive powers by law through assuming his military role.”). This is equally true when it comes to our provision of foreign aid. When President Kennedy first called for the establishment of USAID, he noted that “[c]lose consultation and cooperation with the Congress and its Committees will still be essential, including an annual review of the program.” Kennedy, Special Message to the Congress on Foreign Aid (March 22, 1961). The fact that USAID provides foreign aid does not place it beyond Congress’s purview.

Defendants argue that they have not truly shuttered USAID, but rather are exercising their broad discretion in “‘how best to marshal [their] resources and personnel to carry out [their] delegated responsibilities.’” Mot. at 20 (quoting Massachusetts v. EPA, 549 U.S. 497, 527 (2007)). It is certainly true that the Executive must have some degree of discretion in carrying out its duties to execute the laws. But that “broad discretion” is not unlimited. Massachusetts v. EPA, 549 U.S. at 527. Additionally, I believe that Defendants’ framing of their actions misses the mark.

Here, as the district court found as a matter of fact, Defendants have de facto shut down USAID such that it cannot carry out its congressionally delegated functions. Does 1-26, 2025 WL 840574 at *18 (“The record demonstrates that Defendants, as well as other government officials, have acted swiftly to shut down, dismantle, and effectively eliminate USAID as an independent agency.”). The court found that Musk and the DOGE team were responsible for closing USAID headquarters and taking down its website. See id. at *13–14 (referencing Musk’s posts on X that it was “Time for [USAID] to die,” that “we’re in the process of . . . shutting down USAID,” and that “We spent the weekend feeding USAID into the wood chipper.”). Musk’s actions initiated the end of USAID, leading to what will be the end of the United States’ humanitarian aid to foreign countries.

I believe that when the Executive branch systematically guts an agency such that it cannot carry out its congressionally designated role, it has stepped beyond the bounds of its constitutional authority. As the district court found, this is exactly what has happened here. Id. at *19 (“[a]s a result of these and other actions, USAID appears to be unable to perform its core functions and even certain basic functions of a governmental agency.”). I do, therefore, think that the Executive branch has unconstitutionally invaded the role of the Legislature, upsetting the separation of powers.

II.

The separation of powers question is assuredly of great, and even existential, import: That the Executive does not infringe upon the Legislative branch’s powers is and has always been a pillar of American democracy. In this context, the challenge brought under the Appointments Clause, see U.S. Const. Art. II § 2, cl. 2, may seem less consequential, as Defendants could engage in an easy “fix” by simply adhering to the constitutionally mandated processes. In some ways, I agree, and could rest the merits finding on the separation of powers question. But the Appointments Clause, too, is a bastion of our democratic system and serves as yet another crucial check on the limits of Executive power. As Alexander Hamilton wrote, “the most sacred duty and the greatest source of security in a Republic” is “[a]n inviolable respect for the Constitution and Laws.” Alexander Hamilton, Tully No. III (Aug. 28, 1794). To ignore any unconstitutionality is a failing of that duty. I therefore write to explain why I believe Plaintiffs’ Appointments Clause claim—separately and in addition to their separation of powers claim—is also likely meritorious.

The Appointments Clause of the Constitution was born from colonists’ frustration and distrust with how government offices were filled. At the time of our nation’s founding, “[t]he ‘manipulation of official appointments’ had long been one of the American revolutionary generation’s greatest grievances against executive power.” Freytag v. C.I.R., 501 U.S. 868, 883 (1991) (quoting Gordon Wood, The Creation of The American Republic 1776–1787, 79 (1969)). To address this grievance, and after great debate at the Constitutional Convention, the Framers created the Appointments Clause, which, according to Hamilton, was the best plan “to promote a judicious choice of men for filling the offices of the Union.” The Federalist No. 76 (Alexander Hamilton).

Under the Appointments Clause, “Officers of the United States,” who are “distinct from mere employees” by virtue of their roles, must be appointed through one of two permissible methods. Lucia v. SEC, 585 U.S. 237, 241, 244 n.3 (2018). “Principal Officers” may be appointed only by the President, with the advice and consent of the United States Senate. Id. at 244 n.3. “Inferior Officers” may be appointed in the same manner, or, if Congress so provides, they may be appointed by “the President alone,” by a federal court, or by the head of a department. Id. The Appointments Clause “is more than a matter of ‘etiquette or protocol’; it is among the significant structural safeguards of the constitutional scheme.” Edmond v. United States, 520 U.S. 651, 659 (1997) (quoting Buckley v. Valeo, 424 U.S. 1, 125 (1976)).

It was paramount to our Framers––and must remain paramount today––that the President cannot bypass this structural safeguard and unilaterally select Officers to wield incredible power without legislative oversight of that process. To do so returns us to the very monarchy that our Framers fought and wrote against. But that seems to be exactly what the Executive Branch and Musk have done. It is undisputed that Musk was not duly appointed through either of the permissible methods outlined above. The Senate never had the opportunity to provide its advice and consent on his appointment, nor did Congress create the amorphous and omnipotent Office he now occupies. Thus, according to Plaintiffs, because Musk nevertheless carried out the functions of an Officer, he has violated the Appointments Clause.

The question is now whether Musk is acting as an Officer of the United States. An individual constitutes an “Officer” if they (1) “exercise[] significant authority pursuant to the laws of the United States,” and (2) “occupy a ‘continuing’ position established by law.” Lucia, 585 U.S. at 245 (cleaned up). The Majority merely states that Musk’s “role satisfies neither criterion” but does not explain its reasoning. Maj. Order at 8. I have come to the opposite conclusion, and believe it prudent to set forth my reasoning, as the district court did as well.

A.

As for the first of these two factors––significant authority––our inquiry focuses on “the extent of power an individual wields in carrying out his assigned functions.” Lucia, 585 U.S. at 245; see also Buckley, 424 U.S. at 126. The “main criteria” are “(1) the significance of the matters resolved by the official[], (2) the discretion they exercise in reaching their decisions, and (3) the finality of those decisions.” Tucker v. C.I.R., 676 F.3d 1129, 1133 (D.C. Cir. 2012); see also Carr v. Saul, 593 U.S. 83, 86 (2021) (whether the individual “exercised significant discretion when carrying out important functions” and whether they “often had the last word”) (cleaned up).

It seems plain to me that these three criteria are satisfied. First, the significance of Musk’s actions cannot be overstated. As explained above, the district court found that Musk and DOGE were responsible for closing USAID headquarters and taking down its website. Does 1-26, 2025 WL 840574 at *13–14. Defendants and the Majority question whether Musk was actually responsible for these actions, see Reply Br. at 3, Maj. Order at 7, but provide no evidence to cast doubt on the district court’s factual findings. To me, the record supports the district court’s factual finding that Musk and DOGE directed the effective closure of USAID, impacting the lives of thousands of employees and their families, as well as the lives of governments and individuals worldwide who have for decades relied on our foreign aid. Additionally, the closure of USAID headquarters resulted in the permanent closure of its classified operations center, the significance of which the district court reasonably likened to the closure of the Pentagon for the Department of Defense. See Does 1-26, 2025 WL 840574 at *14.

Musk has taken other incredibly significant actions; as the district court found, Musk was likely responsible for the shutdown of the Consumer Financial Protection Bureau (“CFPB”) as well. See id. at *2 (referencing Musk’s post on X stating “CFPB RIP” hours before that agency’s website and X account were shut down); see Lucia v. SEC, 832 F.3d 277, 284 (D.C. Cir. 2016), rev’d on other grounds, 585 U.S. 237 (2018) (when assessing an Appointments Clause challenge, we should “look not only to the authority exercised in a petitioner’s case but to all of that appointee’s duties”).

Second, Musk has wielded considerable discretion. Again, without any mandate from Congress, Musk and DOGE closed USAID’s headquarters and website, in effect shuttering USAID. That is but one example of the many actions Musk has taken with little oversight. As the President explained, “after he signs an executive order, it gets ‘passed on to [Musk] and his group’ and ‘they’re all getting done.’” Does 1-26, 2025 WL 840574 at *2 (citation omitted). As Musk confirmed, “one of the biggest functions of the DOGE team is just making sure that the presidential executive orders are actually carried out.” Id. (citation omitted). By signing a far-reaching Executive Order, the President acts as a legislature of one; he then hands it off to Musk for execution. This process is contrary to the proper constitutional process and allows Musk to act with substantial discretion, checked only by the President.

Third, Musk’s decisions were final. After he closed the USAID headquarters, the General Services Administration formally cancelled USAID’s occupancy of the building and ordered it transferred to United States Customs and Border Protection. See id. at *3, *15. There was no question that USAID was not to resume operations in that location.

Defendants make a few arguments that I find unavailing. They contend that the lack of formal statutory or regulatory authority granted to Musk “should . . . have been dispositive” on this issue. Mot. at 15; see also Reply Br. at 2. But statutorily-granted decisionmaking authority is not one of the “main criteria” guiding our analysis. Instead, whether authority is “established by law” is only a “threshold trigger,” and “may but need not be the start of an Appointments Clause analysis.” Tucker, 676 F.3d at 1133 n.1; see also Freytag, 501 U.S. at 881 (characteristics that make an individual an employee, rather than an Officer, are if the “position[] [is] not established by law, and whose duties and functions are not delineated in a statute” as well as the “temporary, episodic basis” and “ministerial tasks” of the role). Next, the parties disagree on Musk’s title and role within the Executive Branch: Defendants characterize his position as merely that of a Presidential advisor, Mot. at 4, which the Majority seems to endorse, Maj. Order at 7–8, while Plaintiffs contend that Musk is the de facto USDS Administrator, see Resp. Br. at 15–16, which the district court found likely to be true, Does 1-26, 2025 WL 840574 at *18. The Executive cannot evade constitutional requirements by using the title of “Senior Advisor to the President” as a shield. Nor can it use this evasion as a sword to wield unconstitutional power. We must consider Musk’s role and duties themselves, not what his title purports him to be.

The undisputed record evidence supports the district court’s view that Musk does far more than merely advise President Trump. DOGE’s actions and Musk’s statements on X show that he has exercised operational control over USAID and other agencies, even in the absence of a formal grant to do so, and even in light of his title as advisor. See id. at *2–3, *14, *17 (discussing Musk’s actions toward USAID, CFPB, National Weather Service, United States Department of Agriculture, National Nuclear Security Administration, and Federal Emergency Management Agency). Many of Musk’s directives “thwart th[e] chain of command” necessary to close congressionally-created agencies, as he instead acts unilaterally. Lofstad v. Raimondo, 117 F.4th 493, 500 (3d Cir. 2024). Musk has publicly spoken on behalf of DOGE at a joint press conference with the President on February 11 and in a joint interview with the President on February 18. Does 1-26, 2025 WL 840574 at *2, *17.

Defendants emphasize the district court’s acknowledgement that they “presented evidence that most of the major actions taken at USAID . . . were actually approved by USAID officials,” rebutting the idea that Musk was in control. See Mot. at 17 (citing Does 1-26, 2025 WL 840574 at *13) (emphasis added). The Majority seizes on this idea that “most of the actions about which plaintiffs complain were approved or ratified by Rubio, Marocco and other USAID officials.” Maj. Order at 6 (emphasis added). The key word is most. While the district court did find that most of Musk’s actions challenged by Plaintiffs were subject to the oversight of others––and correctly so––at least some of Musk’s actions were done unilaterally. Thus, even if accepting that Musk-directed actions are the exception, and the majority of Musk’s work is of an advisory nature, subject to others’ approval––although, I must say, I am incredulous of this on the broader scale––the fact that those actions far exceed the bounds of mere advice, without his having been duly appointed, constitutes a significant departure from the protections that undergird our constitutional system.

Additionally, President Trump has indicated that he considers Musk to be acting far beyond an advisory capacity, and instead that he has entrusted Musk to direct agency action. Such presidential statements carry great weight. See Texas v. United States, 809 F.3d 134, 185 (5th Cir. 2015) (relying on presidential statements at the preliminary injunction stage), aff’d by an evenly divided court, 579 U.S. 547 (2016) (per curiam). Significantly, President Trump publicly stated, “I signed an order creating the Department of Government Efficiency and put a man named Elon Musk in charge.” Does 1-26, 2025 WL 840574 at *2 (citation omitted). And when discussing DOGE’s role in implementing Executive Orders, President Trump stated that “[Musk] would take that executive order that I’d signed, and he would have those people go to whatever agency it was – ‘When are you doing it? Get it done. Get it done.’” Id. (citation omitted); see also id. (citations omitted) (Trump stating that Musk is a “leader” of DOGE; that DOGE was “headed by Elon Musk;” that one of the biggest functions of DOGE was to “mak[e] sure that the presidential executive orders are actually carried out”). The President also invited Musk to a Cabinet meeting, signifying that he believed that Musk had the authority equivalent to that of Senate-confirmed Cabinet members. See id. at *3.

Such duties and functions exceed that of an advisory nature and demonstrate authority, contrary to the Defendants’ assertions and the Majority’s belief. Accordingly, I agree with the district court that the present record support the finding that “at least during the time period relevant to this Motion, Musk was, at a minimum, likely the official performing the duties and functions of the USDS Administrator.” Id. at *18. Furthermore, even if viewed under the auspices of his Presidential advisor title, “the record of his activities” shows that Musk was “the leader of the DOGE, with the same duties . . . as if he were formally in that position.” Id.

Although Musk was not formally granted authority by statute or regulation, he has exerted actual authority that only an Officer can exercise––and therein lies the problem. Without being tethered to any formal grant of authority, and without having been duly appointed in accordance with our Constitution.

B.

The next factor in our analysis is whether the individual occupies a “continuing position.” Lucia, 585 U.S. at 245 (internal quotation marks omitted). To be an Officer of the United States, the individual’s duties must be “continuing and permanent, not occasional or temporary.” United States v. Germaine, 99 U.S. 508, 511–12 (1878). The Supreme Court has since held that in certain circumstances, even if a position is time-limited, it can still be that of an Officer. See Morrison, 487 U.S. at 671 n.12, 682–83. There are “three factors that are helpful to consider in determining whether a temporary position is an office: (1) the position is not personal to a particular individual; (2) the position is not transient or fleeting; and (3) the duties of the position are more than incidental.” United States v. Donzinger, 38 F.4th 290, 297 (2d Cir. 2022).

First, I believe that the position is not personal to Musk. Defendants argue that Musk’s advisory role is specific to him, and “there is no indication that [his] particular role as a ‘Senior Advisor to the President’ will outlast his tenure.” Mot. at 17. But again, one’s title––i.e., that of Presidential advisor––should not blind us from reality. As the district court found as a factual matter, the truth is that Musk is acting as the de facto USDS administrator, which heads the U.S. DOGE Service Temporary Organization, as well as the leader of DOGE more broadly. This is substantiated by the significant actions Musk has taken, as well as information from the Executive Branch. See Does 1-26, 2025 WL 840574 at *17; see also Exec. Order No. 14,158, 90 Fed. Reg. at 8,441 (DOGE Executive Order renamed the United States Digital Service as the United States DOGE Service (“USDS” or “DOGE”) and created U.S. DOGE Service Temporary Organization, which is headed by the USDS Administrator); Does 1-26, 2025 WL 840574 at *2 (citation omitted) (President Trump stating that Elon Musk is “in charge” of DOGE); id. at *3 (citation omitted) (the same day that the White House announced that Amy Gleason was the Acting USDS Administrator, it also stated that “the President tasked Elon Musk to oversee the DOGE effort” while others, ostensibly Gleason, “are helping run DOGE on a day-to-day basis”); id. (at the hearing before the district court, Defendants were unable to identify who served as Acting USDS Administrator between January 20, 2025, when DOGE was created, and February 25, 2025, when Gleason was named as Acting USDS Administrator).

Neither the DOGE Executive Order nor any subsequent orders have indicated that the USDS Administrator position is limited to only Musk. See Exec. Order No. 14,158, 90 Fed. Reg. at 8,441; Exec. Order No. 14,170, 90 Fed. Reg 8,621; Exec. Order No. 14,222, 90 Fed. Reg. 11,095. And, as the district court found, “at various times other individuals, including Vivek Ramaswamy and Amy Gleason, have been referenced by the President or the White House as being a leader of DOGE.” Does 1-26, 2025 WL 840574 at *16.

Musk is unique: never before in our Republic have we seen a non-appointed individual wield such immense power and control over government operations. Even the Majority acknowledges that Musk’s role and actions are “unconventional.” Maj. Order at 8. However, as the head of DOGE and the U.S. DOGE Service Temporary Organization, Musk’s role is not unique or personal to him.

Second, his position is not transient nor fleeting. The DOGE Executive Order did not put a time limit on the existence of DOGE, which was renamed and whose functions were redirected from the then-United States Digital Service. See Exec. Order No. 14,158, 90 Fed. Reg. at 8,441, sec. 3(a). I do acknowledge that the Executive Order provided for the “Establishment of a Temporary Organization,” that being the “U.S. DOGE Service Temporary Organization,” which “shall terminate” after an eighteen-month term. See id., sec. 3(b). But the Supreme Court has clarified that a “continuing” position need not be permanent. See Morrison, 487 U.S. at 671 n.12, 682–83 (explaining that “it is clear that [the independent counsel] is an ‘officer’ of the United States, not an ‘employee,’” even where the position was terminated when the counsel’s duties were completed, such that “there remains no need for any continuing action”). What matters is the ongoing nature of the duties during that admittedly finite time period.

In Germaine, the Supreme Court found that a surgeon who was “only to act when called on by the Commissioner of Pensions in some special case,” such that “[h]e may make fifty of these examinations in a year, or none,” was not an Officer, as his duties were “occasional and intermittent.” 99 U.S. at 512. Similarly, in Auffmordt v. Hedden, the Court found that merchant appraiser is “an expert, selected as an emergency arises” to “aid in ascertaining the value of the goods,” and “acts only occasionally and temporarily.” 137 U.S. 310, 326–27 (1890). The facts here are quite different. Musk’s duties are robust, wide, and ongoing, as the district court thoroughly explained, see Does 1-26, 2025 WL 840574 at *16, and he takes significant actions on a daily basis. Even if we are to assume that he has no “responsibilities that extend beyond the accomplishment of the mission” of the U.S. DOGE Service Temporary Organization, Morrison, 487 U.S. at 672––that is, to “advanc[e] the President’s 18-month DOGE agenda,” Exec. Order No. 14,158, 90 Fed. Reg. 8441, sec. 3(b)––his position can still be a “continuing” one at this time.

Third and finally, Musk’s position is more than incidental to the regular operations of government. The district court deftly addressed this factor, and I think there can be no doubt about its having been satisfied. The import of “the DOGE duties described in the executive orders and the actual work conducted, which include the carrying out of presidential directives relating to reducing the number of regulations, addressing waste in grants and contracts, and determining the appropriate size of the federal workforce,” speak for themselves. Does 1-26, 2025 WL 840574 at *17.

The President has made clear that he intends for Musk to be an ongoing, omnipresent fixture in American government. But under our Appointments Clause, it is up to Congress to determine which employees will maintain this extensive and extending control.

Musk has been given and does exert significant authority, and his position as head of DOGE and de facto USDS Administrator is robust and ongoing. He therefore acts as an Officer of the United States. But he does so without the required congressional authorization—either in the form of a Senate confirmation or a congressionally created office. Accordingly, Defendants have likely violated the Appointments Clause.

III.

As my above discussion of Plaintiffs’ claims clearly indicates, I believe that the district court properly held that Plaintiffs had established a likelihood of success on the merits as to the unconstitutionality of Defendants’ actions in dismantling USAID. But that does not end the analysis. As an Article III court, we are constrained to decide only the cases or controversies properly before us. The district court could not enjoin these unconstitutional actions because the proper defendants were not before it. However, Plaintiffs otherwise would have standing to pursue the relief they seek.

Courts can and have adjudicated cases seeking to invalidate allegedly unconstitutional Executive actions in the past. See, e.g., Biden v. Nebraska, 600 U.S. 477 (2023) (seeking declaratory relief against then President and Secretary of Education); Trump v. Hawaii, 585 U.S. 667 (2018) (bringing action against President, Executive Branch officials and agencies, and the United States, seeking to prohibit implementation and enforcement of Presidential Proclamation barring nationals from predominantly Muslim countries); Zivotofsky, 576 U.S. 1 (2015) (bringing action for declaratory and injunctive relief against Secretary of State); Rumsfeld v. Forum for Acad. & Institutional Rights, Inc., 547 U.S. 47 (2006) (challenging constitutionality of statute authorizing the Secretary of Defense to deny funding to educational institutions that prohibited on-campus military recruiting). But in those cases, the agency and often the Executive were named as defendants.

After the district court found that Musk and DOGE were responsible for dismantling USAID, the question then became: what’s next? The Majority correctly identifies, the constitutional violation and the remedy cannot go both ways: if Musk and DOGE lack the authority to order USAID officials to do anything, enjoining Musk to direct USAID officials to restore employment, building access, and security services, among other relief, also cannot stand. Plaintiffs did not name defendants with the proper authority to effectuate the relief that Plaintiffs seek. Suing Musk and DOGE constrained the court’s ability to redress their constitutional claims, which I have noted above, and as the district court found as a matter of fact, were quite strong.

I do take issue with the Majority’s minimization of the very real and irreparable harms suffered by Plaintiffs and their implied concern regarding standing. As the district court found, the Plaintiffs have suffered numerous actual injuries and face an imminent threat of additional injuries. See Does 1-26, 2025 WL 840574 at *9, *27–29; see also Scotts Co. v. United Indus. Corp., 315 F.3d 264, 283 (4th Cir. 2002) (plaintiffs “must make a clear showing of irreparable harm[,] . . . and the required irreparable harm must be neither remote nor speculative, but actual and imminent.”) (cleaned up); TransUnion LLC v. Ramirez, 594 U.S. 413, 437 (2021) (recognizing that emotional injury is sufficient to establish Article III standing).

Further, I differ with the Majority’s concern about the broad scope of the preliminary injunction, which it perceives as affording broad and structural constitutional relief that is mismatched with the Plaintiffs’ claims. This is a mischaracterization of the relief sought. Plaintiffs’ prayer for relief seeks to enjoin an unconstitutional Executive action to dismantle an agency, much like any other challenge to Executive actions as being unlawful. For example, the Supreme Court struck down a prior administration’s student loan forgiveness program in its entirety despite only one state establishing standing through one loan servicer. See Biden v. Nebraska, 600 U.S. at 549 (Kagan, J. dissenting) (“So no proper party is before the Court. A court acting like a court would have said as much and stopped.”). The Court found that harm to plaintiffs, financial and otherwise, gave standing to seek invalidation of the illegal actions leading to that harm. Thus, an injunction preventing further harm in a case like this one would be entirely consistent with recent Supreme Court precedent. See, e.g., id. at 491.

In addition, the fact that, here, the Executive has taken many likely unconstitutional actions that, collectively, dismantled an agency, rather than just a single action, does not mean the court cannot render those actions invalid. The sheer number of illegal actions taken necessitates relief that consists of “vast and detailed actions,” Maj. Order at 14, to adequately redress the harms caused by the illegal shutdown of a government agency. Rather than “micromanag[ing]” the Executive, Mot. at 22, the Court was simply attempting to remedy each of the likely illegal actions.

The judiciary is limited to the cases and controversies before it. These Plaintiffs, suing these Defendants, cannot obtain the relief that they seek.

_______________

[b]Notes:


1 The Majority questions this characterization of the results of Defendants’ actions. Maj. Order at 7. But, in doing so, it improperly meddles in factual determination properly left to the discretion of the district court. Second guessing factual findings of a district court in an emergency stay posture where the applicant has not even asserted that such findings were erroneous, let alone clearly so, is entirely inappropriate. As we have long held, a party seeking reversal of a district court’s injunction order must “overcome a deferential standard of appellate review.” Pierce v. N.C. State Bd. of Elections, 97 F.4th 194, 210 (4th Cir. 2024). We evaluate a district court’s decision to grant a preliminary injunction under an abuse of discretion standard and only review the district court’s factual findings for clear error. Id.; see also Roe v. Dep’t of Def., 947 F.3d 207, 219 (4th Cir. 2020). Indeed, “[w]here there are two permissible views of the evidence, the [district court’s] choice between them cannot be clearly erroneous.” Id. (citing Anderson v. City of Bessemer City, 470 U.S. 564, 574 (1985)).

2 The statute defined “a reorganization, redesign, or other plan shall include any action to—

(1) expand, eliminate, consolidate, or downsize covered departments, agencies, or organizations, including bureaus and offices within or between such departments, agencies, or organizations, including the transfer to other agencies of the authorities and responsibilities of such bureaus and offices;

(2) expand, eliminate, consolidate, or downsize the United States official presence overseas, including at bilateral, regional, and multilateral diplomatic facilities and other platforms; or

(3) expand or reduce the size of the permanent Civil Service, Foreign Service, eligible family member, and locally employed staff workforce of the Department of State and USAID from the staffing levels previously justified to the Committees on Appropriations for fiscal year 2024.

Id. at § 7063(b).
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Re: Anti-Anti-Nazi Barbarian Hordes are Knocking Down the Ga

Postby admin » Wed Apr 02, 2025 8:26 pm

Judge pauses Trump administration plans to end deportation protection for Venezuelans
by The Associated Press
March 31, 20259:52 PM ET
https://www.npr.org/2025/03/31/nx-s1-53 ... eportation

Image

https://www.courtlistener.com/docket/69 ... ce-v-noem/

https://ia601403.us.archive.org/10/item ... 8.93.0.pdf

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

NATIONAL TPS ALLIANCE, et al.,

Plaintiffs,

v.

KRISTI NOEM, et al.,

Defendants.

Case No. 25-cv-01766-EMC

ORDER GRANTING PLAINTIFFS’
MOTION TO POSTPONE


Docket No. 16


SAN FRANCISCO (AP) — A federal judge on Monday paused plans by the Trump administration to end temporary legal protections for hundreds of thousands of Venezuelans, a week before they were scheduled to expire.

The order by U.S. District Judge Edward Chen in San Francisco is a relief for 350,000 Venezuelans whose Temporary Protected Status was set to expire April 7 after Homeland Security Secretary Kristi Noem reversed protections granted by the Biden administration.

Chen said in his ruling that the action by Noem "threatens to: inflict irreparable harm on hundreds of thousands of persons whose lives, families, and livelihoods will be severely disrupted, cost the United States billions in economic activity, and injure public health and safety in communities throughout the United States."

He said the government had failed to identify any "real countervailing harm in continuing TPS for Venezuelan beneficiaries" and said plaintiffs will likely succeed in showing that Noem's actions "are unauthorized by law, arbitrary and capricious, and motivated by unconstitutional animus."

Chen, who was appointed to the bench by President Barack Obama, a Democrat, said his order in the lawsuit brought by the National TPS Alliance applies nationally.
Noem had also announced the end of TPS for an estimated 250,000 additional Venezuelans in September.

The judge gave the government one week to file notice of an appeal and the plaintiffs one week to file to pause for 500,000 Haitians whose TPS protections are set to expire in August. Alejandro Mayorkas, the previous secretary, had extended protections for all three cohorts into 2026.

"Today is a good day for the migrant community in this country," said Pablo Alvarado, co-executive director of the National Day Laborer Organizing Network.

He said that people fleeing war-torn El Salvador who initially benefited from the TPS program fought to maintain protections that came to include countries such as Ukraine, Sudan and Syria — and the broader community must continue fighting.

"It takes so much courage to come forward and say, 'Here I am, and I'm going to fight for this,'" Alvarado said. "We're not going to throw anyone under the bus. We're going to fight for everyone because everyone is deserving."

The Department of Homeland Security did not immediately respond to a request for comment.

Congress created TPS, as the law is known, in 1990 to prevent deportations to countries suffering from natural disasters or civil strife, giving people authorization to live and work in the U.S. in increments of up to 18 months if the Homeland Security secretary deems conditions in their home countries are unsafe for return.

The reversals are a major about-face from immigration policies under former President Joe Biden, a Democrat, and come as Republican President Donald Trump and his top aides have ratcheted up attacks on judges who rule against them, with immigration being at the forefront of many disagreements.

At a hearing last Monday, lawyers for TPS holders said that Noem has no authority to cancel the protections and that her actions were motivated in part by racism. They asked the judge to pause Noem's orders, citing the irreparable harm to TPS holders struggling with fear of deportation and potential separation from family members.

Government lawyers for Noem said that Congress gave the secretary clear and broad authority to make determinations related to the TPS program and that the decisions were not subject to judicial review. Plaintiffs have no right to thwart the secretary's orders from being carried out, they said.

But Chen found the government's arguments unpersuasive and said that numerous derogatory and false comments by Noem — and by Trump — against Venezuelans as criminals show that racial animus was a motivator in ending protections.

"Acting on the basis of a negative group stereotype and generalizing such stereotype to the entire group is the classic example of racism," he wrote.


Biden sharply expanded use of TPS and other temporary forms of protection in a strategy to create and expand legal pathways to live in the United States while suspending asylum for those who enter illegally.

Trump has questioned the the impartiality of a federal judge who blocked his plans to deport Venezuelan immigrants to El Salvador, levelling his criticism only hours before his administration asked an appeals court to lift the judge's order.

The administration has also said it was revoking temporary protections for more than 530,000 Cubans, Haitians, Nicaraguans and Venezuelans who have come to the U.S. since October 2022 through another legal avenue called humanitarian parole, which Biden used more than any other president. Their two-year work permits will expire April 24.
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Re: Anti-Anti-Nazi Barbarian Hordes are Knocking Down the Ga

Postby admin » Wed Apr 02, 2025 8:43 pm

Image

https://www.courtlistener.com/docket/69 ... er_by=desc

https://ia601309.us.archive.org/2/items ... .153.0.pdf

UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY

MAHMOUD KHALIL,

Petitioner,

v.

WILLIAM P. JOYCE, et al.,

Respondents.

No. 25-cv-01963 (MEF)(MAH)

OPINION and ORDER

Table of Contents

I. Background
A. The Facts
B. Procedural History
C. The Motion
D. The Court’s Approach
II. Legal Principles
III. Law of the Case
A. General Principles
B. “The Same Issue”
C. Implicitly “The Same Issue”
D. Discretion
E. Conclusion
IV. What Supplies Jurisdiction
A. The Respondent’s Argument
B. Section 1631
1. The Court Can Look to Section 1631
2. Section 1631 Applies to Habeas Petitions
3. Section 1631 Applies Here
4. Section 1631 Covers Personal Jurisdiction
5. What Section 1631 Means Here
a) Miller
b) Martinez-Nieto
c) Other Cases
V. Section 1631 and Two Further Issues
VI. The Endo Rule
A. Background
B. Consensus Understanding
VII. The Immediate Custodian Rule
A. The Louisiana Warden
B. The New Jersey Warden
1. Facts
2. The Unknown Custodian Exception
3. Applying the Unknown Custodian Exception
a) ”If Known”
b) The District of Confinement Rule
c) Conclusion
VIII. Conclusion and Next Steps

* * *

A lawful permanent resident was detained, and filed a habeas corpus petition seeking his release.

The respondents, various federal officials, have moved to dismiss, arguing the Court does not have jurisdiction.

The motion is denied.


*****************

Federal Judge Rules Mahmoud Khalil’s Immigration Case Must Continue in New Jersey
Headline
by Amy Goodman
DemocracyNow!
Apr 02, 2025

A federal judge has ruled in favor of Mahmoud Khalil, allowing the Palestinian Columbia University student protest leader to challenge his detention and deportation in a New Jersey court. The order is seen as a victory for Khalil, as this is the second time a federal judge has denied the Trump administration’s request to transfer the case to the state of Louisiana, where Khalil has been held at an ICE jail for nearly one month. His legal team continues to fight for his release. In a statement, Khalil’s wife Noor Abdalla said, “This is an important step towards securing Mahmoud’s freedom, but there is still a lot more to be done. As the countdown to our son’s birth begins and I inch closer and closer to my due date, I will continue to strongly advocate for Mahmoud’s freedom and for his safe return home so he can be by my side to welcome our first child.”
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Re: Anti-Anti-Nazi Barbarian Hordes are Knocking Down the Ga

Postby admin » Wed Apr 02, 2025 9:00 pm

Trump Sends Hundreds of Immigrants to Brutal Salvadoran Prison as Mass Deportations Expand
by Amy Goodman
DemocracyNow
April 02, 2025
https://www.democracynow.org/2025/4/2/t ... transcript



Since President Donald Trump took office, the U.S. has expelled hundreds of immigrants and asylum seekers to El Salvador without due process to be detained at the supermax mega-prison complex known as CECOT, with many of them accused of belonging to gangs largely on the basis of having tattoos. The Trump administration recently admitted in a court filing that a Salvadoran father with protected status was among those sent to El Salvador. Kilmar Armando Abrego Garcia lived in Maryland with his family and had been granted protected status in 2019, blocking the federal government from removing him. Despite admitting to an “administrative error,” the Trump administration says it will not seek to return Abrego Garcia to his family. “Every single day now, new stories are coming out showing that they made a lot of mistakes,” says Aaron Reichlin-Melnick, a senior fellow at the American Immigration Council. “Their goal is to ramp up deportations and arrests as quickly as they can, and if that leads to a bunch of innocent people getting swept up alongside, the message that the White House is sending is they don’t care.”

Transcript

This is a rush transcript. Copy may not be in its final form.

AMY GOODMAN: This is Democracy Now!, democracynow.org, The War and Peace Report. I’m Amy Goodman, with Juan González.

We look now at how the Trump administration has transferred another group of immigrants to a supermax mega-prison complex in El Salvador. U.S. Secretary of State Marco Rubio said Monday 17 immigrants from Venezuela and El Salvador accused of being gang members have been sent to the Salvadoran mega-prison Sunday, after previously being detained at Guantánamo Bay Naval Base in Cuba.

Since Trump took office, the U.S. has expelled hundreds of immigrants and asylum seekers to El Salvador without due process, accusing many of belonging to gangs largely on the basis of having tattoos. One Venezuelan asylum seeker now held in the Salvadoran prison was removed for tattoos on each forearm that read “mom” and “dad.”


This week, the U.S. admitted in a court filing that a Salvadoran dad with protected status was also among the hundreds of immigrants who were transferred to El Salvador. He was living with his family in Maryland. Kilmar Armando Abrego had been granted protected status in 2019, blocking the federal government from sending him back to El Salvador after he fled gang violence there. The Trump administration said Garcia was removed, quote, “because of an administrative error,” and that, though, it could not bring him back, because it’s now in custody of — he’s in custody of El Salvador.

Conservatives, like MAGA podcaster Joe Rogan, are also joining in speaking out against the removal of a professional makeup artist accused of being a gang member, calling the case “horrific.”

JOE ROGAN: You’ve got to get scared that people who are not criminals are getting, like, lassoed up and deported and sent to, like, El Salvador prisons. … This is kind of crazy that that could be possible. That’s horrific. And that’s — again, that’s bad for the cause. Like, the cause is let’s get the gang members out. Everybody agrees. But let’s not innocent gay hairdressers get lumped up with the gangs. And then, like, how long before that guy can get out? Like, can we — can we figure out how to get him out?

AMY GOODMAN: This comes as U.S. District Judge Edward Chen in San Francisco has temporarily blocked the Trump administration’s efforts to end deportation relief and work permits for hundreds of thousands of Venezuelan immigrants with temporary protected status.


Image

https://www.courtlistener.com/docket/69 ... ce-v-noem/

https://ia601403.us.archive.org/10/item ... 8.93.0.pdf

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

NATIONAL TPS ALLIANCE, et al.,

Plaintiffs,

v.

KRISTI NOEM, et al.,

Defendants.

Case No. 25-cv-01766-EMC

ORDER GRANTING PLAINTIFFS’
MOTION TO POSTPONE


Docket No. 16


For more, we go to Washington, D.C., where we’re joined by Aaron Reichlin-Melnick, senior fellow at the American Immigration Council.

Aaron, thanks so much for being with us again. Can you explain what is happening right now? Talk about the Maryland dad from El Salvador who was just deported to this human rights-abusing mega-prison. The administration is paying Bukele, the president of El Salvador, millions to hold these immigrants and asylum seekers.

AARON REICHLIN-MELNICK: Yeah. So, on March 15th, the Trump administration sent three planes full of people to El Salvador, with people they claimed were members of MS-13 or the Venezuelan gang Tren de Aragua. The problem is, every single day now new stories are coming out showing they made a lot of mistakes. And over the weekend, we found out for the first time that they made a mistake that they are admitting. And that was the deportation of a Maryland dad, Kilmar Abrego Garcia, who was sent there despite the fact that an immigration judge in 2019 ruled that he had protection from being deported to El Salvador. It was illegal to send him to El Salvador. And so, now the Trump administration has had to admit they made a mistake there.

But more and more evidence suggests this was a rushed operation where they shoved as many people onto those planes as they could that had been entered in a database somewhere as Tren de Aragua, and they never really bothered to check whether or not that was true. They just looked at people’s tattoos and said, “Well, you know, we have an intelligence report that says people from Tren de Aragua have tattoos with crowns on them, so any person who has a crown on their body that’s tattooed is a Tren de Aragua member. We don’t need to go any further than that.” And that’s basically the level of due process people got.


They weren’t even told that they were being sent there, though. New stories coming out today confirms every person who was sent there was lied to and told that they were going to be deported to Venezuela, and they didn’t find out ’til they landed in El Salvador what had actually happened.

JUAN GONZÁLEZ: Well, Aaron, even after the admission of the administration, in terms of Abrego Garcia’s case, Vice President JD Vance posted on the social media platform X that, quote, “he was a convicted MS-13 gang member with no legal right to be here.” Could you comment on that?

AARON REICHLIN-MELNICK: Yeah, that’s just simply false. And I’ll take each one of those in turn. Convicted: He’s not been convicted of anything. Mr. Abrego Garcia arrived here in 2011 as a 16-year-old fleeing the gangs himself, who had threatened to kill him if he didn’t join them. He, like many thousands of youth that left El Salvador in that period, came to the United States seeking safety, and for the last 14 years has not gotten into any serious trouble with the law at all. He’s been convicted of nothing.

But what happened is, in 2019, he was looking for day labor outside of a Home Depot in Maryland, and local cops arrested him and three other men there. Those local cops interrogated him, demanded to know whether he was connected to a gang. He denied it continuously. And then a local police detective wrote on a gang worksheet that a confidential informant had allegedly claimed that this guy was a member of a gang, a part of MS-13 that operated in Long Island. Mr. Abrego Garcia has never lived in Long Island, and he said, “This is ridiculous.” And when his lawyers, in 2019, tried to reach back out to the police to talk to the detective and say, “Hey, why did you put this down here?” they found out that the detective had been suspended, and the local police didn’t even have a record of his arrest. So, that is the only — only — evidence that the government has ever offered that he is connected to MS-13. And despite that arrest, which did not lead to charges, he has never been charged or convicted of a crime once in his life.

He also did win protection. In 2019, that arrest led to him being sent to ICE detention. He was locked in ICE detention for almost a year. And at the end, a judge granted him a protection known as “withholding of removal,” that said, “You are more likely than not to be persecuted if sent to El Salvador, so the one thing the government cannot do is deport you to El Salvador.” And that’s exactly what happened on March 15th.

JUAN GONZÁLEZ: Well, you recently testified in front of the Committee on Homeland Security, the Subcommittee on Border Security and Enforcement, that Trump’s diversion of thousands of law enforcement officers to mass deportation is actually creating a greater national security risk. Could you explain that?

AARON REICHLIN-MELNICK: Yeah, so, the most important thing that people need to know about what the Trump administration is doing — well, one of the most important things — is that they have turned the entire U.S. federal law enforcement apparatus into an immigration enforcement apparatus. President Trump has diverted thousands of federal law enforcement officers away from their normal duties and told them to go carry out immigration arrests instead. One in four DEA agents, that normally are out there tracking down drug rings, are now involved in immigration enforcement instead. Eighty percent of ATF investigators are now doing immigration enforcement. They’ve taken people from the IRS who are specialized in investigating financial crimes, and they’re doing immigration enforcement. And even troublingly, they’re taking the FBI’s Joint Terrorism Task Force and making them do immigration enforcement. And Homeland Security Investigations, where investigators have the job of protecting children from sexual predators online, those people have been taken off of their duties of going after pedophiles and have been told that they have to do immigration enforcement instead. None of that is making the country safer. It’s just transforming the entire country into a dragnet for immigrants, while letting a lot of other people doing some pretty bad things off the hook.

AMY GOODMAN: Let me ask you about the U.S. District Judge Edward Chen in San Francisco temporarily blocking the Trump administration’s efforts to end deportation relief and work permits for hundreds of thousands of Venezuelan immigrants in TPS — with TPS. Some, what, a third of a million have TPS. They could face mass deportation. In his ruling, the judge said that Homeland Security Secretary Kristi Noem’s move to terminate TPS for Venezuelans will, quote, “inflict irreparable harm on hundreds of thousands of persons whose lives, families, and livelihoods will be severely disrupted, cost the [U.S.] billions in economic activity, and injure public health and safety in communities throughout the United States.” The significance of this, in this minute we have left, Aaron?

AARON REICHLIN-MELNICK: It’s enormous. There are potentially 350,000 people who are going to lose their job on April 7th, and another 300,000 in September, and then potentially 500,000 Haitians coming up this fall, as well. And what Judge Chen ruled is, if you want to terminate TPS, you’ve got to go through the right procedures, and you can’t do it based on false claims that hundreds of thousands of Venezuelans are all Tren de Aragua and criminals, when the status is only available to people with no criminal record.

JUAN GONZÁLEZ: Yeah, and what do you think in terms of the numbers that the Trump administration is claiming, more than 100,000 people deported so far in his administration?

AARON REICHLIN-MELNICK: Yeah, those numbers seem likely incorrect. They don’t fit the — the Trump administration said yesterday they had also done 110,000 arrests already. That suggests they did 70,000 arrests in the last two weeks. I think somebody in the administration made a mistake.

But what we know is, these are the numbers they want. Their goal is to ramp up deportations and arrests as quickly as they can, and if that leads to a bunch of innocent people getting swept up alongside, the message that the White House is sending is they don’t care. As long as they hit their numbers, who cares who is on those planes? They just want to get them out of the country.

AMY GOODMAN: Federal judge has —

AARON REICHLIN-MELNICK: Due process be damned.

AMY GOODMAN: A federal judge has ordered the Trump administration to restore funds to programs that provide legal services to unaccompanied minors, to children, in immigration proceedings. Ten seconds.

AARON REICHLIN-MELNICK: Great news. Children need lawyers. No child should have to face deportation in court alone. And the Trump administration wanted to strip away federally funded lawyers that Congress set aside money for.

AMY GOODMAN: We’re going to leave it there. Aaron Reichlin-Melnick, senior fellow at the American Immigration Council. I’m Amy Goodman, with Juan González, for another edition of Democracy Now!
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Re: Anti-Anti-Nazi Barbarian Hordes are Knocking Down the Ga

Postby admin » Wed Apr 02, 2025 10:33 pm

A “Coup” at Columbia? Former Law Prof. Katherine Franke on School’s Capitulation to Trump
by Amy Goodman
DemocracyNow
April 02, 2025
https://www.democracynow.org/2025/4/2/u ... transcript



Princeton has become the latest university to be targeted by the Trump administration, as the federal government pauses dozens of federal grants to the school. The news comes after the Trump administration threatened to cut off more than $8.7 billion to Harvard and earlier suspended $175 million in federal funding to the University of Pennsylvania and $400 million to Columbia University. In all cases, the Trump administration has claimed to be fighting antisemitism, citing the schools’ responses to student-led campus protests in solidarity with Gaza. “It’s time for us to step back … and think more critically about how we run our universities,” says former Columbia law professor Katherine Franke, who says students from abroad, even those with green cards and U.S. citizenship, are now “terrified” of being swept up in the Trump administration’s crackdown. “It feels like a kind of racial and ethnic cleansing that is happening on our campuses.”

Transcript

This is a rush transcript. Copy may not be in its final form.

AMY GOODMAN: This is Democracy Now!, democracynow.org, The War and Peace Report. I’m Amy Goodman, with Juan González.

Princeton has become the latest university to be targeted by the Trump administration. The federal government is pausing dozens of federal grants to Princeton. The news came a day after the Trump administration threatened to cut off nearly $9 billion to Harvard over the school’s response to student-led campus protests in solidarity with Gaza. Earlier, the Trump administration had suspended $175 million in federal funding to the University of Pennsylvania and $400 million to Columbia University. At Columbia, the board of trustees responded by agreeing to a series of demands from President Trump in an effort to keep the federal funding.

This all comes as Columbia is in a state of turmoil. On Friday, Columbia’s interim President Katrina Armstrong resigned as president. Columbia’s board of trustees then elevated its own board co-chair, Claire Shipman, the journalist, to become the school’s new interim president.

Meanwhile, Mahmoud Khalil, a Palestinian Columbia student protest leader, remains locked up in an immigration jail in Louisiana more than three weeks after he was abducted by ICE agents at his Columbia University housing, after appealing to the president of Columbia to help him. On Tuesday, a federal judge in New Jersey ruled Khalil’s lawsuit should move forward to New Jersey, where Khalil was taken before being sent to Louisiana.


Image

https://www.courtlistener.com/docket/69 ... er_by=desc

https://ia601309.us.archive.org/2/items ... .153.0.pdf

UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY

MAHMOUD KHALIL,

Petitioner,

v.

WILLIAM P. JOYCE, et al.,

Respondents.

No. 25-cv-01963 (MEF)(MAH)

OPINION and ORDER

Table of Contents

I. Background
A. The Facts
B. Procedural History
C. The Motion
D. The Court’s Approach
II. Legal Principles
III. Law of the Case
A. General Principles
B. “The Same Issue”
C. Implicitly “The Same Issue”
D. Discretion
E. Conclusion
IV. What Supplies Jurisdiction
A. The Respondent’s Argument
B. Section 1631
1. The Court Can Look to Section 1631
2. Section 1631 Applies to Habeas Petitions
3. Section 1631 Applies Here
4. Section 1631 Covers Personal Jurisdiction
5. What Section 1631 Means Here
a) Miller
b) Martinez-Nieto
c) Other Cases
V. Section 1631 and Two Further Issues
VI. The Endo Rule
A. Background
B. Consensus Understanding
VII. The Immediate Custodian Rule
A. The Louisiana Warden
B. The New Jersey Warden
1. Facts
2. The Unknown Custodian Exception
3. Applying the Unknown Custodian Exception
a) ”If Known”
b) The District of Confinement Rule
c) Conclusion
VIII. Conclusion and Next Steps

* * *

A lawful permanent resident was detained, and filed a habeas corpus petition seeking his release.

The respondents, various federal officials, have moved to dismiss, arguing the Court does not have jurisdiction.

The motion is denied.


We’re joined now by Katherine Franke, former professor at Columbia Law School.

Welcome back to Democracy Now! So, how unusual is it? I mean, this is now the third woman, the first three women, to be president of Columbia University. First it was Minouche Shafik, and now Katrina Armstrong being fired and replaced by the board co-chair, the board of trustees co-chair?

KATHERINE FRANKE: Well, what we’re seeing is a continuation and an escalation of the board of trustees of Columbia University basically going rogue. There was also a report issued yesterday by the Columbia University Senate, almost 400-page report, documenting the ways in which the trustees abused their power over the last two years in mismanaging events at Columbia. So, Claire Shipman being appointed, outside of the normal process, president at Columbia is part of that pattern of really a takeover of the university by the trustees, by these corporate officers of the university, who quite clearly have demonstrated that they do not feel any fidelity to protecting our academic mission, but, in a way, are working hand in glove with the Trump administration to destroy that very mission.

JUAN GONZÁLEZ: And, Katherine, when you say the board is going rogue, what would be the normal process for the selection of a president at Columbia?

KATHERINE FRANKE: Well, Juan, I’m glad you asked. I brought Columbia’s charters and statutes with me. And one section within there very clearly says that where a president or an acting president has stepped down, resigned or otherwise stepped down from office, the provost is supposed to become the acting president, until such time as the trustees conduct a regular search, that would involve many stakeholders in the university community. But instead of allowing Angela Olinto, who is the provost of Columbia, who I think is widely well regarded and, I think, would have been welcomed as an acting president by everyone in our community — instead of that, following the rules of the statutes, they appointed their own co-chair of the board of trustees.

And, Juan, I have to say it feels like Columbia University has become the Tesla of the U.S. academic community, where wealthy people buy their way onto the board of trustees and then appoint themselves CEO of the organization, only to ruin the brand of that institution. No one in their right mind wants a Tesla right now, and people are heading for the doors at Columbia. The admissions just went out for the undergraduate program, and the numbers are way down. Students don’t want to come to Columbia. So it feels very similar, that we have this kind of hostile takeover of our institution, the one that you’ve had a long legacy with, Juan, that mirrors what’s happening in other parts of the country, as well.

JUAN GONZÁLEZ: And I wanted to ask you about this, the Trump administration’s threat to cut off $400 million in federal funding to the university that forced it to back down on some key issues. Columbia has, by my last reading, a $14.8 billion endowment. It could easily have replaced that $400 million for the four terms of the — four years of the Trump administration from its own endowment, which I suspect that’s what an endowment is for, for emergency situations. What is your sense of how these universities over the last decades, by depending largely on either corporate donors or federal grants, have put themselves in a bind where they’re basically under control by outside forces?

KATHERINE FRANKE: Well, I think that’s exactly right, that the business model of a university, particularly large research universities like Columbia, is one that has come, over the last many years, to depend so heavily on federal money for its budget. It’s the largest part of our budget, that along with the fees and other income we get from running the medical school. It’s not tuition. It’s not major donors. It’s those two: the federal money and the medical school income. And when we are in alignment with the U.S. government, that’s a great thing. But when we’re not, we’re incredibly vulnerable. And so, I think this is a moment where all universities — and higher education, more generally — needs to have a kind of reckoning of a new kind of business model of how to run a university, that isn’t so incredibly dependent upon shifts in the political winds in our country.

Now, I don’t actually think that the endowment is going to save our problem. Much of those funds in Columbia’s endowment, which is the smallest endowment of all of the Ivy League schools, I’ll note, are tied up in ways where they have to be allocated to particular funding streams. They can’t just be reappropriated to fund or replace those federal grants. And it, in any event, would be a short-term Band-Aid. There’s too much of the budget to cover with these federal grants that have been pulled. It’s $400 million-plus now, but it will be a lot more. You look at Harvard, they’re talking about billions of dollars. The endowment can’t possibly fill that gap.

So it’s time for us to think about things like why are faculty or, more importantly, university presidents paid so much.

Breakdown of College President Compensation
https://www.ivycoach.com/the-ivy-coach- ... residents/

Note that the list below was compiled using IRS tax returns from fiscal year 2021. It may not — and, in some cases, it does not — reflect the current leadership status of the schools listed below.

Rank / President / Institution / Total Compensation / Base Pay

1 / Amy Gutmann / University of Pennsylvania / $22,866,127 / $1,564,547
2 / Lee C. Bollinger / Columbia University / $3,865,304 / $1,625,998
3 / Andrew Hamilton / New York University / $3,554,120 / $3,341,125
4 / Carol L. Folt / University of Southern California / $3,479,049 / $1,419,861
5 / Robert J. Zimmer / University of Chicago / $3,427,953 / $1,427,443
6 / Stephen K. Klasko / Thomas Jefferson University / $3,419,856 / $1,993,309
7 / Paul E. Klotman / Baylor College of Medicine / $2,788,571 / $1,500,000
8 / Joseph E. Aoun / Northeastern University / $2,717,178 / $1,072,561
9 / John A. Fry / Drexel University / $2,599,636 / $765,164
10 / Paula S. Wallace / Savannah College of Art and Design / $2,583,936 / $1,198,542
11 / Daniele Struppa / Chapman University / $2,580,730 / $703,863
12 / Morton O. Schapiro / Northwestern University / $2,539,838 / $1,196,409
13 / Shirley Ann Jackson / Rensselaer Polytechnic Institute / $2,443,727 / $2,107,787
14 / Ronald J. Daniels / Johns Hopkins University / $2,400,646 / $1,442,580
15 / Gordon F. Tomaselli / Albert Einstein College of Medicine / $2,356,627 / $886,957
16 / Thomas F. Rosenbaum / California Institute of Technology / $2,239,837 / $1,408,059
17 / Peter Salovey / Yale University / $2,228,014 / $1,366,930
18 / Dennis S. Charney / Icahn School of Medicine at Mount Sinai / $2,165,155 / $1,100,000
19 / John R. Raymond / Medical College of Wisconsin / $2,093,020 / $1,077,565
20 / Julio Frenk / University of Miami / $2,077,289 / $1,228,683
21 / Stuart Rabinowitz / Hofstra University / $2,003,023 / $559,259
22 / Christina Paxson / Brown University / $1,982,296 / $1,068,875
23 / Laurie Leshin / Worcester Polytechnic Institute / $1,982,083 / $901,231
24 / Vincent E. Price / Duke University / $1,975,805 / $1,533,626
25 / Daniel Diermeier / Vanderbilt University / $1,962,597 / $1,211,163


We need to think about who gets paid and valued within the university. It is those very researchers in the medical school who make many times more in salary from a philosophy professor or an English professor at Columbia, in part as a reward for the fact that they’ve been drawing these federal funds to underwrite the university’s business model. So, it’s time for us to step back and not say, “Oh, the piggy bank is going to save us,” but actually think more critically about how we run our universities.

AMY GOODMAN: I wanted to turn to Jeff Sovern. He’s one of the four children of Columbia University’s first Jewish president, Michael Sovern. On Tuesday, Democracy Now! reached Jeff and asked him to read out loud the open letter he and his siblings just published in The Washington Post.

March 13, 2025

Dr. Katrina Armstrong
Interim President
Columbia University
Office of the President
202 Low Library
535 W. 116 St., MC 4309
New York, NY 10027

David Greenwald
Claire Shipman
Co-Chairs
Columbia Board of Trustees
202 Low Library
535 W. 116 St. MC 4309
New York, NY 10027

Dear Dr. Armstrong:

Please consider this a formal response to the current situation on the campus of Columbia University and a follow up to our letter of March 7, 2025, informing you that the United States Government would be pausing or terminating federal funding. Since that date your counsel has asked to discuss “next steps.”

U.S. taxpayers invest enormously in U.S. colleges and universities, including Columbia University, and it is the responsibility of the federal government to ensure that all recipients are responsible stewards of federal funds. Columbia University, however, has fundamentally failed to protect American students and faculty from antisemitic violence and harassment in addition to other alleged violations of Title VI and Title VII of the Civil Rights Act of 1964. Pursuant to your request, this letter outlines immediate next steps that we regard as a precondition for formal negotiations regarding Columbia University’s continued financial relationship with the United States government. Please ensure and document compliance with the following no later than the close of business on Wednesday, March 20, 2025:

● Enforce existing disciplinary policies. The University must complete disciplinary
proceedings for Hamilton Hall and encampments. Meaningful discipline means expulsion or multi-year suspension.
● Primacy of the president in disciplinary matters. Abolish the University Judicial Board (UJB) and centralize all disciplinary processes under the Office of the President. And empower the Office of the President to suspend or expel students with an appeal process through the Office of the President.
● Time, place, and manner rules. Implement permanent, comprehensive time, place, and manner rules to prevent disruption of teaching, research, and campus life.
Mask ban. Ban masks that are intended to conceal identity or intimidate others, with exceptions for religious and health reasons. Any masked individual must wear their Columbia ID on the outside of their clothing (this is already the policy at Columbia’s Irving Medical Center).
● Deliver plan to hold all student groups accountable. Recognized student groups and individuals operating as constituent members of, or providing support for, unrecognized groups engaged in violations of University policy must be held accountable through formal investigations, disciplinary proceedings, and expulsion as appropriate.
● Formalize, adopt, and promulgate a definition of antisemitism. President Trump’s Executive Order 13899 uses the IHRA definition. Anti-“Zionist” discrimination against Jews in areas unrelated to Israel or Middle East must be addressed.

5. GERMAN ZIONISM OFFERS TO COLLABORATE WITH NAZISM

Werner Senator, a leading German Zionist, once remarked that Zionism, for all its world Jewish nationalism, always politically assimilates to the countries within which it operates. No better proof of his remark exists than the political adaptation of the ZVfD to the theories and policies of the new Nazi regime. Believing that the ideological similarities between the two movements -- their contempt for liberalism, their common volkish racism and, of course, their mutual conviction that Germany could never be the homeland of its Jews -- could induce the Nazis to support them, the ZVfD solicited the patronage of Adolf Hitler, not once but repeatedly, after 1933.

The goal of the ZVfD became an 'orderly retreat', that is, Nazi backing for emigration of at least the younger generation of Jews to Palestine, and they immediately sought contact with elements in the Nazi apparatus whom they thought would be interested in such an arrangement on the basis of a volkish appreciation of Zionism. Kurt Tuchler, a member of the ZVfD Executive, persuaded Baron Leopold Itz Edler von Mildenstein of the SS to write a pro-Zionist piece for the Nazi press. The Baron agreed on the condition that he visited Palestine first, and two months after Hitler came to power the two men and their wives went to Palestine; von Mildenstein stayed there for six months before he returned to write his articles. [86]

Contact with a central figure in the new government came in March 1933, when Hermann Goering summoned the leaders of the major Jewish organisations. In early March, Julius Streicher, the editor of Der Steurmer, had declared that, as of 1 April, all Jewish stores and professionals would be boycotted; however, this campaign ran into an immediate snag. Hitler's capitalist backers were extremely worried by the announcement by rabbi Wise of a planned counter-demonstration to be held in New York on 27 March, if the Nazis went ahead with their boycott. Jews were prominent throughout the retail trade both in American and Europe and, fearing retaliation against their own companies, Hitler's wealthy patrons urged him to call off the action. But the Nazis could hardly do that without losing face, and they decided to use German Jewry to head off Wise; thus Hermann Goering called in the Jewish leaders....

-- Zionism in the Age of the Dictators: A Reappraisal [EXCERPT], by Lenni Brenner


● Empower internal law enforcement. The University must ensure that Columbia security has full law enforcement authority, including arrest and removal of agitators who foster an unsafe or hostile work or study environment, or otherwise interfere with classroom instruction or the functioning of the university.
● MESAAS Department – Academic Receivership. Begin the process of placing the Middle East, South Asian, and African Studies department under academic receivership for a minimum of five years. The University must provide a full plan, with date certain deliverables, by the March 20, 2025, deadline.
● Deliver a plan for comprehensive admissions reform. The plan must include a strategy to reform undergraduate admissions, international recruiting, and graduate admissions practices to conform with federal law and policy.

We expect your immediate compliance with these critical next steps, after which we hope to open a conversation about immediate and long-term structural reforms that will return Columbia to its original mission of innovative research and academic excellence.

Sincerely,

Josh Gruenbaum
Comm'r of the Fed. Acquisition Serv.
General Services Administration

Thomas E. Wheeler
Acting General Counsel
U.S. Dept. of Education

Sean R. Keveney
Acting General Counsel
U.S. Dep't Health & Human Servs.


JEFF SOVERN: Our father, Michael I. Sovern, was the first Jewish president of Columbia University, which he served for more than 60 years. We believe that if he were alive today, he would be disgusted by the government’s coercion of Columbia, purportedly in the name of our religion. We don’t believe that President Donald Trump is sincere about protecting Jews from antisemitism. We find it more likely that an administration whose vice president has agreed with Richard M. Nixon that “professors are the enemy” is using antisemitism as a pretext to damage Columbia and America’s other elite universities. …

Our father is one of only three people interred on his beloved Columbia campus. Trump’s attack on the university desecrates a place our family holds sacred. It is both plausible and disturbing that some at Columbia are antisemitic. But we do not believe attempts to force the university to relinquish its independence are an appropriate response. And we wish the Trump administration would stop gaslighting us all.


AMY GOODMAN: Again, that is Jeff Sovern, one of the four children of Columbia University’s first Jewish president, Michael Sovern. He was reading from an open letter he and his siblings had published in The Washington Post. Professor Katherine Franke, you taught at Columbia for close to a quarter of a century. You ultimately were forced to retire around your support for pro-Palestinian students, Jewish students, Muslim students, students who consider themselves atheists, whatever, but who all share their concern about Israel’s assault on Gaza. Can you talk about what he’s saying and this hammer of accusations of antisemitism, equating them with anti-Zionism?

KATHERINE FRANKE: Well, Michael Sovern was an incredible president of our university. And his office, after he stepped down from being president, was down the hall from me, so I saw him daily. He led the university through very difficult times and actually was president when I was an undergraduate at Columbia — at Barnard. Columbia didn’t admit women at the point that I was an undergrad. And so, his children’s statement resonates so strongly with those of us who knew President Sovern very well.

I know that Lee Bollinger, our most recent — well, not most recent president, because we’ve had so many, but our most recent long-term president — is also, finally, expressing real concerns about the leadership at the university. And I’ve spoken to a number of the former provosts, who feel that Columbia has lost its way in the name of protecting Jewish students — some Jewish students — from bias.

And, of course, we shouldn’t have any form of antisemitism on our campus, but this is being used as a fig leaf for a political project. If Columbia really cared about eradicating all forms of bias from our university, then Columbia would have done something seriously about one of my male colleagues at the law school who uses the N-word in class regularly, a white male colleague who thinks that’s funny and makes him cool, or another who tells slavery jokes to Black students in the classroom and thinks that’s a very funny and appropriate thing to do in the classroom. And the Black students in those classes brought complaints to the administration, and nothing happened.

So we have an overreaction in the case of antisemitism — and again, I don’t want to say that there aren’t any incidents; there always are forms of antisemitism in all the institutions we’re part of — but we have absolutely no reaction to issues of sexism, racism, homophobia, etc. In fact, they’ve taken all that language down off the university’s website at this point. I have trans colleagues at Columbia who are afraid for their own safety in the law school building. So, the environment is not one that has made any of us feel safer. It is one in which our safety has been weaponized in the name of advancing this larger political project, which is ultimately, I think, about dismantling the very university itself.

JUAN GONZÁLEZ: And, Katherine, I wanted to ask you about the Trump administration’s campaign of terror, really, against international students, revoking immigration statuses. The Times of India reports that the State Department has emailed hundreds of international students, asking them to self-deport for allegedly participating in campus activism. The United States has long been a place where students from all around the world come to study here. What’s the impact of this on not just Columbia, but all universities across the country?

Hundreds of international students wake up to an email asking them to self deport for campus activism
by Lubna Kably
The Times of India
March 30, 2025

Hundreds of international students in the US are getting an email from the US Department of State (DOS) asking them to self-deport owing to campus activism. Immigration attorneys’ contacted by TOI affirmed this development and added a few Indian students may also be at the receiving end of such emails – for something as innocuous as sharing a social media post.

It is not just international students who physically participated in campus activism but also those who shared or liked ‘anti-national’ posts that are the target of these emails, said an immigration attorney.

This crackdown is based on social-media reviews being conducted by DOS (which includes Consulate officials). Thus, even new student applications be it for an F (academic study visa), M (vocational study visa) or J (exchange visa) will also come under such social media scrutiny. Applicants will be denied the opportunity to study in the US.

According to the latest Open Doors report, there are 1.1 million international students studying in the US in 2023-24 of which 3.31 lakh are Indian students.

As reported by Axios earlier, Marco Rubio, Secretary of State, has launched an AI-fuelled ‘Catch and Revoke’ effort to cancel the visas of foreign nationals who appear to support Hamas or other designated terror groups. Axios further reports that more than 300 foreign students have had their student visas revoked in the three weeks that ‘Catch and Revoke’ has been in operation, there are 1.5 million student visa-holders nationwide.

The email sent to the students reads:

“On behalf of the United States Department of State, the Bureau of Consular Affairs Visa Office hereby informs you that additional information became available after your visa was issued. As a result, your F-1 visa with expiration date XXXXX was revoked in accordance with Section 221(i) of the United States Immigration and Nationality Act, as amended."

"The Bureau of Consular Affairs Visa Office has alerted the Department of Homeland Security’s Immigration and Customs Enforcement, which manages the Student Exchange Visitor Program and is responsible for removal proceedings. They may notify your designated school official about the revocation of your F-1 visa."

"Remaining in the United States without a lawful immigration status can result in fines, detention, and/or deportation. It may also make you ineligible for a future U.S. visa. Please note that deportation can take place at a time that does not allow the person being deported to secure possessions or conclude affairs in the United States. Persons being deported may be sent to countries other than their countries of origin."

"Given the gravity of this situation, individuals whose visa was revoked may wish to demonstrate their intent to depart the United States using the CBP Home App"

"As soon as you depart the United States, you must personally present your passport to the U.S. embassy or consulate which issued your visa so your visa can be physically cancelled. You must not attempt to use your visa as it has been revoked. If you intend to travel to the United States in the future, you must apply for another U.S. visa and a determination on your eligibility for a visa will be made at that time."


According to immigration attorneys, the flurry of self-deportation emails that are being sent to international students stems from a March 25, internal directive dispatched by Rubio, directing mandatory social media reviews of existing international students already in the US and new applicants.

“If the social media review uncovers potentially derogatory information indicating that the applicant may not be eligible for a visa, Fraud Prevention Units are required to take screenshots of social media findings to the extent it is relevant to a visa ineligibility, to preserve the record against the applicant's later alteration of the information,” states this internal directive.

“Consular officers do not need to upload social media findings if the review does not reveal derogatory information, but consular officers must enter case notes stating they conducted a social media review which did not reveal derogatory information,” adds the directive.

Such students are also being informed by their International Student Service Office that their SEVIS record has been terminated. SEVIS is the web-based information system that the US Department of Homeland Security (DHS) uses to track and monitor international students during their duration of study.

“Students with a terminated SEVIS record must depart the U.S. immediately; there is no grace period following a SEVIS termination. We advise you to depart the US as soon as possible," states this intimation.

Views of an immigration attorney:

Jath Shao, founder of an immigration law firm, spoke extensively with TOI on this emerging issue.

“F-1 and J-1 students are usually admitted D/S, meaning for the duration of their status. There’s a slight distinction between overstay and unlawful presence Historically, someone admitted D/S has not accrued unlawful presence for the purpose of 3 or 10 year bars unless USCIS makes a formal finding that they are unlawfully present. This is important because if you're formally unlawfully present for more than 180 days or 365 days, it can trigger a 3 or 10 year bar. However, with overstay, it's more in a gray area - where the consular officer has more discretion whether to hold that overstay or status violation against the person,” said Shao.

“USCIS’s page has been updated recently on Jan 25 and now states that – Non-immigrants admitted for the duration of status, generally begin accruing unlawful presence the day after their status ends, if they remain in US,” he pointed out.

This is similar to what the Trump administration had attempted during his earlier tenure, when they tried to change the rule to backdate unlawful presence to the point of time when the person violated status.

“Historically, someone admitted under D/S can stay as long as they are maintaining that status - such as being a full time F-1 student or J-1 exchange visitor. In cases of SEVIS termination, normally there are two things an international student can do - either apply to USCIS to reinstate your F-1 and SEVIS, or leave the US and try to get a new F-1 visa through the embassy.”

Shao added, “As part of the leaked Rubio memo (reported by online media) states that affected people should self deport and report to the US consulate or embassy for physical cancellation of their visa, it doesn’t seem like going back to apply for a new visa would be a great option.” (The email sent to a student, as seen by TOI, also has a similar wording).

Jath Shao and other immigration attorneys view that students should seek legal counsel to help them reinstate their SEVIS or in a worse case, immigration attorneys can defend them if removal proceedings are brought against them.

Rubio’s statement at an earlier press conference:

At a press conference in Guyana on Thursday, in response to a question relating to the Turkish student at Tufts who has been detained, Rubio said:

“if you apply for a visa to enter the United States and be a student and you tell us that the reason why you’re coming to the United States is not just because you want to write op-eds, but because you want to participate in movements that are involved in doing things like vandalizing universities, harassing students, taking over buildings, creating a ruckus, we’re not going to give you a visa. If you lie to us and get a visa and then enter the United States and with that visa participate in that sort of activity, we’re going to take away your visa.”

“Now, once you’ve lost your visa, you’re no longer legally in the United States, and we have a right, like every country in the world has a right, to remove you from our country. So it’s just that simple.”

“I think it’s crazy – I think it’s stupid for any country in the world to welcome people into their country that are going to go to their universities as visitors – they’re visitors – and say I’m going to your universities to start a riot, I’m going to your universities to take over a library and harass people. I don’t care what movement you’re involved in. Why would any country in the world allow people to come and disrupt? We gave you a visa to come and study and get a degree, not to become a social activist that tears up our university campuses. And if we’ve given you a visa and then you decide to do that, we’re going to take it away…Once your visa is revoked, you’re illegally in the country and you have to leave. Every country in the world has a right to decide who comes in as a visitor and who doesn’t”.


KATHERINE FRANKE: Well, Juan, I can’t overstate how terrified our students are. And it’s not just the students who are on visas or even green cards. It’s all of our students who come from other countries, who may even be citizens at this point, because it seems there’s no limit to the ways in which this administration is going to both test and violate the law in cleansing — it feels like a kind of racial and ethnic cleansing that is happening on our campuses.

One of the reasons I loved being a Columbia professor was that in many of my classes, half of the students came from other countries. They brought their experiences, their wisdom, other — notions of other legal systems, other cultures into the classroom, and it made it such a rich learning environment. I learned so much from them.

And when I talk to my colleagues now — I’m not teaching anymore, but I’m hearing that those students are not saying a word. And some of them are not even coming onto campus anymore, because they’re afraid of getting nabbed and of having the administration actually turn over their cellphones and home addresses. So, the classes are actually being emptied of those voices and of those bodies. And it’s a loss for the Columbia community, but it’s a horrible form of terror for the actual students who are so frightened.


AMY GOODMAN: As we talk about what’s happening to students, I wanted to end — we only have about a minute. On Tuesday, a federal judge in New Jersey ruled that Mahmoud Khalil — he was the negotiator between the students and Columbia University; he was a grad student at SIPA, who had a green card — that his case — he was taken from Columbia University housing; his green card was revoked; taken away from his wife, who is about to give birth; and sent to a Louisiana ICE jail. The judge in New Jersey ruled his case should move forward in New Jersey, where he was taken before being sent to Louisiana. What’s happening in this case? You were an adviser to Mahmoud Khalil.

KATHERINE FRANKE: I worked very closely with him for a year and a half, as did the university. They picked him as the student that they wanted to sit in the middle, between the students that were protesting and the administration itself, because they knew he was mature, he was reasonable, everyone trusted him. He was the exactly right person to be the negotiator between the university and the students. And then they put a target on his back, essentially, by allowing untruths to circulate in social media and elsewhere, to come out of the mouth of the secretary of state and other Trump administration officials. You know, it just breaks my heart, Amy, to see what’s happening to him and his family, but not only them.

He is still in that detention center, that horrible place in Louisiana, even though the case is in New Jersey. And his lawyers are fighting very hard — I know all of them well — to get him moved. His case has been moved, but he has not been moved. And they’re still making arguments to the judge to bring Mahmoud home, so that he’ll be — home-ish, in New Jersey, so that he’ll be closer to his family and to his lawyers. It is a horrendous object lesson of how the institutions that you think you’re part of and can trust turn on you, whether it’s Columbia or the United States government, and how hard it is to then bring him back to a place of security and freedom. And we’re all just hoping that these next arguments in court will bring Mahmoud back at least to a detention center in New Jersey, which is better than where he is now.


AMY GOODMAN: Katherine Franke, former professor at Columbia Law School, she was there for a quarter of a century, forced to retire in January.
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Postby admin » Thu Apr 03, 2025 8:45 pm

Remarkable Things in the Government’s Alien Enemies Act Briefs to the Supreme Court
by Marty Lederman
Juustsecurity.org
April 3, 2025
https://www.justsecurity.org/109967/sup ... emies-act/

https://www.supremecourt.gov/docket/docketfiles/html/public/24a931.html

Supreme Court Docket, Case No. 24A931
Title: Donald J. Trump, President of the United States, et al., Applicants v. J.G.G., et al.
Docketed: March 28, 2025
Lower Ct: United States Court of Appeals for the District of Columbia Circuit, Case Numbers: (25-5067)

Date, Proceedings and Orders

Mar 28 2025 Application (24A931) to vacate the orders issued by the United States District Court for the District of Columbia, submitted to The Chief Justice.
Main Document Proof of Service
Mar 28 2025 Response to application (24A931) requested by The Chief Justice, due by 10 a.m. (EDT), on April 1, 2025.
Mar 31 2025 Amicus brief of American Rights Alliance not accepted for filing. (To be corrected and resubmitted - April 1, 2025)
Mar 31 2025 Amicus brief of APA Watch submitted.
Main Document
Mar 31 2025 Amicus brief of South Carolina, Virginia, and 25 Other States submitted.
Main Document Proof of Service
Apr 01 2025 Motion for Leave to File Amicus Curiae Brief in Support of Appellants-Defendants by the American Rights Alliance not accepted for filing. (April 1, 2025)
Apr 01 2025 Response to application from respondents J.G.G., et al. filed.
Main Document Main Document Main Document Proof of Service
Apr 01 2025 Amicus brief of Representative Brandon Gill not accepted for filing. (April 01, 2025) (corrected brief to be submitted)
Apr 01 2025 Brief amicus curiae of American Rights Alliance filed.
Main Document
Apr 01 2025 Amicus brief of Democracy Defenders Fund and Conservatives submitted.
Main Document Proof of Service
Apr 01 2025 Amicus brief of Representative Brandon Gill submitted.
Main Document
Apr 02 2025 Reply of applicants Donald J. Trump, et al. filed.
Reply Proof of Service


As many readers know, Chief Judge Jeb Boasberg has issued and extended temporary restraining orders that prohibit the Trump Administration from removing potentially hundreds of individuals from the United States before next Saturday (April 12) pursuant to a Presidential Proclamation purporting to invoke the Alien Enemies Act, which the White House made public, and which thus took effect, on March 15. (The most comprehensive description of the basis for Boasberg’s orders is found in his March 24 memorandum denying the government’s motion to vacate the TROs.) Boasberg is convening a hearing next Tuesday to decide whether to grant plaintiffs’ request for a preliminary injunction, which would prohibit such removals beyond April 12.

In the meantime, the Acting Solicitor General has asked the Supreme Court to vacate the TROs. In my humble opinion, that application for vacatur, and the government’s reply brief in support of it that the Acting SG filed yesterday, fall considerably short of the historical standards for quality and forthrightness that typify briefs that the Office of the Solicitor General files in the Supreme Court. Whether or not the Justices (or others) agree with that general assessment, I thought it would be useful to quickly highlight several of the more remarkable things about the reply brief the Acting SG filed yesterday, given that the Justices might be considering the application on a very expedited basis. (For readers seeking a more detailed understanding of what the case is about, the ACLU’s brief in opposition to the Acting SG’s application contains much more comprehensive responses to the arguments in the Government’s opening brief. And the ACLU’s recently filed memorandum in support of its motion for a preliminary injunction includes a far more detailed description of what’s been happening with respect to the individuals transferred to the brutal El Salvador prison pursuant to the President’s implausible invocation of the Enemy Aliens Act of 1798.).

Here are four of the most troubling aspects of the Acting SG’s briefs:

1. The legal basis for the Government’s request that the Supreme Court vacate the TROs is fairly discrete and somewhat technical. The Acting SG argues that because each of the hundreds of individuals in question can challenge their removal from the U.S. pursuant to the AEA Proclamation in individual habeas corpus petitions in the districts where they are being detained—which for many or all of them is the Southern District of Texas—the Administrative Procedure Act (APA) precludes them from bringing a class action for prospective relief from removal pursuant to the APA itself, which is what they’ve done in the suit before Boasberg in the U.S. District Court for the District of Columbia. As the Acting SG puts it, “respondents cannot obtain relief because they brought the wrong claims in the wrong court.”

As I note in Point 2 below, I think this argument for habeas exclusivity is dubious, and the Acting SG does not even engage with the principal Supreme Court precedents that bear on the issue. The ACLU argues likewise. The ACLU brief also explains to the Court, however, that the Government’s proposed alternative (and thus, in the Government’s view, the exclusive) means of challenging removal—individual habeas petitions—is chimerical, largely because the Trump Administration would likely whisk the individuals off to an El Salvadoran prison as soon as the TROs are no longer in effect, thereby effectively precluding any meaningful opportunity for judicial review via habeas. That became evident with the government’s admissions in the appellate oral argument below. This is how Judge Patricia Millett of the U.S. Court of Appeals for the D.C. Circuit starkly put the point in her opinion last week:

The government’s position at oral argument was that, the moment the district court TROs are lifted, it can immediately resume removal flights without affording Plaintiffs notice of the grounds for their removal or any opportunity to call a lawyer, let alone to file a writ of habeas corpus or obtain any review of their legal challenges to removal. Oral Arg. 1:44:04-1:45:51. It is irreparable injury to reduce to a shell game the basic lifeline of due process before an unprecedented and potentially irreversible removal occurs.


In response to this concern, the Acting SG offers this cryptic sentence in her reply brief: “[T]his Office has been informed that aliens detained pursuant to the AEA receive notice that they are detained pursuant to the AEA, and could thus bring habeas petitions to challenge that detention, even if they cannot challenge the notice itself or collaterally attack removal as in a Title 8 proceeding.” (Emphasis added.)

A few things are especially noteworthy about this rather inscrutable sentence. First, of course, is the fact that the awkward passive-voice assertion (“has been informed”) does not identify who has “informed” the SG’s Office, what evidence they offered to support the assertion, or the nature of the alleged notice to the covered individuals. At the very least, it leaves a factual uncertainty about which individuals received the notice; from whom; and when. (The named plaintiffs, for example, have represented that they didn’t receive any notice or other paperwork before they were boarded on a plane that would have taken them to El Salvador but for Chief Judge Boasberg’s first TRO.)

Presumably, however, the SG is referring to (though not identifying) this one-page “notice” document, which apparently has been given to some, though perhaps not all, of the covered individuals. Here’s what that document tells an individual who receives it:

You have been determined to be at least fourteen years of age; not a citizen or lawful permanent resident of the United States; a citizen of Venezuela; and a member of Tren de Aragua. Accordingly, you have been determined to be an Alien Enemy subject to apprehension, restraint, and removal from the United States. You are not entitled to a hearing, appeal, or judicial review of this notice and warrant of apprehension and removal. Until you are removed from the United States, you will remain detained under Title 40, Unite[d] States Code, Section 21. (Emphasis added.)


Even if, as the SG suggests, that document informed persons of their right to challenge their alleged AEA detention, the recipients wouldn’t have an obvious reason to challenge that detention, as such, because the government already was detaining each of them under other statutory authority before the President made public (and thus effective) his AEA Proclamation on March 15, and therefore the individuals would continue to be detained even apart from the Proclamation. The important effect of the AEA Proclamation—and the subject of the litigation before the Court—is not to allow the government to detain the individuals, which it was already doing and can continue to do even while the TROs are in effect (a point Boasberg has repeatedly emphasized), nor even to afford the government authority to remove them pursuant to ordinary immigration laws (another point Boasberg has stressed), but instead to provide alleged authority to remove them immediately, and without any notice or time to provide for a hearing, to the Salvadoran prison. Hence, the only notice of any value in this context would be one that unequivocally informs the individuals of a clear right to challenge in court the legality of their immediate removal.

In any event, this notice document does not say—in the words of the Acting SG—that the person “could thus bring habeas petitions to challenge that detention,” let alone that the person can file a habeas petition to challenge their imminent removal from the United States to a Salvadoran prison. To the contrary, it specifically tells the recipient that “[y]ou are not entitled to a hearing, appeal, or judicial review of this notice and warrant of apprehension and removal”! In other words, it appears to be an effort to mislead the individual into thinking that no judicial review is available. That likely explains why the Acting SG fails to point the Court to the document itself—namely, that it appears to undermine the thrust of the SG’s argument about the adequacy of the purported habeas alternative.

What’s more, according to declarations filed with the preliminary injunction motion, the Government does not inform the individuals’ immigration attorneys that they are to be removed pursuant to the AEA. And, from all that appears, many or most of the individuals receive the document in question immediately before they are transferred to planes bound for El Salvador, i.e., well before they might have the understanding and wherewithal to file a habeas petition (even if the notice offered them that information—which it decidedly does not (see above)). From the Government’s perspective, this appears to be a feature, not a bug: As Attorney General Bondi explained to Chief Judge Boasberg just Tuesday in her brief in opposition to the motion for a preliminary injunction, “although aliens who are deemed to fall within the scope of the Proclamation may file a petition for habeas challenging that designation, providing an added layer of procedural safeguards, nothing requires the government to delay removal to permit access to habeas on the alien’s preferred timeline.”

Best I can tell, that’s a barely-disguised euphemism to confirm Judge Millett’s alarm—namely, that although the Trump Administration concedes that each of the individuals in theory has a legal right to file a habeas petition to challenge the legality of their AEA removal from the United States to El Salvador, the Administration is going to make every effort to ensure that they are on the planes en route to El Salvador before they might file any such petitions.

On page 1 of her reply brief, the Acting SG tries to assure the Court that “[t]his case is not about whether TdA members subject to removal under the Alien Enemies Act get judicial review; they obviously do.” In light of the Administration’s practices, however, that wouldn’t be “obvious[]” at all if the Court were to vacate the TROs.

2. The merits of the government’s argument about habeas exclusivity depend upon a reference in 5 U.S.C. 704, which was part of Section 10 of the original APA. Section 704 provides that “[a]gency action made reviewable by statute and final agency action for which there is no other adequate remedy in a court are subject to judicial review” under the APA. The government argues that because individual habeas petitions offer the prospect of “adequate remed[ies],” Section 704 precludes review under the APA, including the sort of class action the ACLU has brought in this case.*

As I explained in Point 1, above, the habeas alternative here is far from “adequate.” More fundamentally, however, the Government’s Section 704 argument would be questionable even if habeas were an adequate alternative means of challenging the legality of the removals. I’m not going to go deep in the weeds here on this question; it suffices to note that the Acting SG does not even grapple with a couple of Supreme Court precedents that point strongly in the other direction.

First, the Court held in Shaughnessy v. Pedreiro, 349 U.S. 48, 52 (1955), that Section 10 of the APA itself provided “a right of judicial review of deportation orders other than by habeas corpus.” See also Zadvydas v. Davis, 533 U.S. 678, 687 (2001) (“Beginning in 1952, an alternative method for review of deportation orders, namely, actions brought in federal district court under the Administrative Procedure Act (APA), became available.”) (citing Pedreiro). (Although Congress in 1961 replaced district court APA review with review in a court of appeals as the “sole and exclusive” procedure for challenging deportation orders issued under the Immigration and Naturalization Act, that preclusion statute didn’t affect removals or deportations made pursuant to other statutes, such as the AEA, which remain subject to APA challenge.)

So what about the “for which there is no other adequate remedy in a court” language in APA Section 10? Notably, neither the Acting SG nor any Justice in Pedreiro suggested that that language precluded APA review, notwithstanding the available habeas alternative. Indeed, that language was “‘almost completely ignored in judicial opinions,’” Bowen v. Massachusetts, 487 U.S. 879, 902 (1988) (quoting Kenneth Culp Davis), for decades, until the SG invoked it in Bowen v. Massachusetts. In that case, the Court explained that Congress include the language in question because “[a]t the time the APA was enacted, a number of statutes creating administrative agencies defined the specific procedures to be followed in reviewing a particular agency’s action; for example, Federal Trade Commission and National Labor Relations Board orders were directly reviewable in the regional courts of appeals, and Interstate Commerce Commission orders were subject to review in specially constituted three-judge district courts.” Id. at 903 (emphasis added). “When Congress enacted the APA to provide a general authorization for review of agency action in the district courts,” the Court explained, “it did not intend that general grant of jurisdiction to duplicate th[ose] previously established special statutory procedures relating to specific agencies.” Id. (emphasis added). Yet the Court made clear that Section 704 “should not be construed to defeat the central purpose of providing a broad spectrum of judicial review of agency action.” Id. Citing Pedreiro itself, the Court in Massachusetts further opined that “[a] restrictive interpretation of § 704 would unquestionably, in the words of Justice Black, ‘run counter to § 10 and § 12 of the Administrative Procedure Act. Their purpose was to remove obstacles to judicial review of agency action under subsequently enacted statutes….’” Id. (quoting Pedreiro, 349 U.S. at 51).

The Government argued in Massachusetts that Section 704 should be construed to bar district court review of the agency action in that case because monetary relief against the United States was available in the Claims Court under the Tucker Act. “This restrictive—and unprecedented—interpretation of § 704 should be rejected,” the Court held, “because the remedy available to the State in the Claims Court is plainly not the kind of ‘special and adequate review procedure’ that will oust a district court of its normal jurisdiction under the APA.” Id. Likewise, a habeas action to challenge a deportation order is plainly not the kind of “special” and agency-specific review procedure that ousts a district court of its usual APA jurisdiction under Section 704.

The ACLU understandably cited Pedreiro and Massachusetts in its brief. Perhaps there is some way of distinguishing them. (I haven’t done extensive research on the question.) Yet the Acting SG does not even mention those precedents in her reply brief, let alone make an effort to explain why they don’t preclude her Section 704 argument.

3. By its terms, the Alien Enemies Act authorizes the removal of enemy foreign nations pursuant to a proper presidential proclamation if those persons “refuse or neglect to depart” from the United States. 50 U.S.C. 21. Thus, as Boasberg explained, “[b]y its plain terms, … the Act withholds from the President or his officers the authority to remove an alien enemy until that person has been given time to decide whether to depart on his own. …. It follows that summary deportation following close on the heels of the Government’s informing an alien that he is subject to the Proclamation—without giving him the opportunity to consider whether to voluntarily self-deport or challenge the basis for the order—is unlawful.”

The Acting SG doesn’t so much as mention this fundamental aspect of the AEA, which would at a minimum provide covered persons a means of returning to their home nations rather than being involuntarily transferred to a Salvadoran prison.

4. On the merits of the President’s authority to issue the Proclamation (which the Court need not decide in the context of this “shadow docket” application), the most obvious reason why the AEA does not authorize the Proclamation is that Tren de Aragua (the TdA) is not a foreign “nation or government,” and thus the persons identified in the Proclamation, even those who are TdA members, are not “natives, citizens, denizens, or subjects” of the TdA, see 50 U.S.C. 21. In order to get around this deficiency, in his Proclamation President Trump purported to find that the TdA is “conducting irregular warfare against the territory of the United States … at the direction … of the Maduro regime in Venezuela.”

Acting at the direction of a government, however, does not transform an individual or a group into a government itself (let alone a nation).

What’s more, the consensus view among executive intelligence agencies fewer than 20 days before Trump’s proclamation reportedly was that the Venezuelan government does not control TdA. (Note also the CIA Director’s and Director of National Intelligence’s admissions before Congress late last month). Presumably that explains why DOJ (wisely) has not relied upon Trump’s “at the direction of the Maduro regime” so-called “finding” in the lower courts. Surprisingly, however, the Acting SG, however—particularly in her opening brief—relies heavily on that finding. In response to the ACLU’s flag about the contrary Intelligence Community view, the Acting SG writes in her reply brief that “respondents’ own source reports internal disagreement among the intelligence agencies, Resp. App. 434a, and it is the President’s prerogative to weigh information from those agencies.” What that “source report” says, however, is merely that the FBI “partly dissented” from the CIA and NSA conclusion, in the sense that the FBI believes that TdA “has a connection to the administration of Venezuela’s authoritarian president, Nicolás Maduro, based on information the other agencies did not find credible.” Even that FBI conclusion, apparently based upon dubious evidence, doesn’t support the view that the Maduro regime “directs” TdA’s so-called “irregular warfare” against U.S. “territory.” (From all that appears, the President modified the term “warfare” with the adjective “irregular” because … what the TdA is doing in the United States is not actually waging the sort of war that can trigger an AEA proclamation. That’s another problem with the Trump Proclamation.)

The President surely can “weigh” competing information from agencies, but he doesn’t have a “prerogative” to make a finding of Maduro “direction” of the TdA if there’s no evidence to support it. (If the President were adhering to the legal requirement that proclamations and executive orders must obtain OLC’s approval for form and legality before being signed, such a “finding” would never have seen the light of day in the absence of supporting evidence. It appears, however, that the President has systematically disregarded the prescribed OLC role, which effectively invites him to issue findings with no factual basis or legal justification.)

– – – – – – – – – – – –

* The Government also argues that “claims at the historical core of habeas may be brought only in habeas,” and asserts that the claims here are “core” habeas claims. For the reasons explained by the ACLU however, this argument borders on the frivolous because the plaintiffs are not challenging their detention (which antedated the AEA proclamation and that presumably would continue even if the Proclamation is declared invalid) but are, instead, challenging the Government’s authority to remove the individuals to El Salvador without complying with any of the ordinary immigration procedures—something far from the “core” of habeas.

Marty Lederman (Bluesky - X) is Executive Editor at Just Security. He is a professor at the Georgetown University Law Center. He served as Deputy Assistant Attorney General at the Office of Legal Counsel from 2021-2023 and 2009-2010, and as an Attorney Advisor at the Office of Legal Counsel from 1994-2002.
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