Filed Date: Feb. 9, 2025
Closed Date: Sept. 19, 2025
Clearinghouse coding complete
This Privacy Act case proceeded in parallel to National Treasury Employees Union v. Vought (1:25-cv-00381), which challenged the broader effort to dismantle the CFPB.
This case challenged the alleged unlawful disclosure of federal employee information by the Consumer Financial Protection Bureau (CFPB) to operatives affiliated with the Department of Government Efficiency (DOGE). On February 9, 2025, the National Treasury Employees Union (NTEU) filed suit in the U.S. District Court for the District of Columbia against Russell Vought in his official capacity as Acting Director of CFPB (ECF 1). NTEU was represented by in-house union counsel.
The case was assigned to Judge Richard J. Leon.
According to the complaint (ECF1), President Trump signed Executive Order 14158 on January 20, 2025, creating DOGE and directing federal agencies to provide its personnel—including so-called “special government employees”—with access to government systems, records, and software. NTEU alleged that beginning February 7, 2025, CFPB complied with the order and granted DOGE personnel, including Elon Musk and three other individuals, access to employee systems and internal databases. These systems allegedly contained sensitive employee information, including personally identifiable information (PII), health records, internal communications, calendar data, and records of union activity.
NTEU alleged that such disclosures violated the Privacy Act of 1974 (5 U.S.C. § 552a), as well as CFPB’s own regulations codified at 12 C.F.R. Part 1070. The union asserted that no applicable exception to the Privacy Act permitted these disclosures. In particular, DOGE personnel were not “officers or employees” of CFPB, and the routine-use exception did not authorize such broad access. NTEU also claimed that the disclosures contravened the Consumer Financial Protection Act and the Trade Secrets Act. It sought declaratory and injunctive relief barring any further disclosure of employee data to DOGE personnel.
On July 21, the government moved to dismiss the case under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6), arguing that NTEU lacked standing and failed to state a claim. The government contended that the union’s claims were speculative and failed to identify a concrete injury traceable to the challenged conduct.
On August 11, 2025, NTEU filed a First Amended Complaint that elaborated its Privacy Act theory and detailed CFPB's s August 2020 System of Records Notice (SORN) for its Employee Administrative Records system, including its enumerated routine uses (ECF 16). The amended pleading added a claim under the Administrative Procedure Act, 5 U.S.C. § 706(2)(A), alleging that CFPB’s DOGE access policy was ‘contrary to law’ because it authorized disclosure of employee records outside any Privacy Act exception. The First Amended Complaint also referenced the Right to Financial Privacy Act and continued to seek declaratory and injunctive relief preventing further disclosure and requiring deletion of any improperly accessed employee PII.
On September 19, 2025, before any ruling on the merits or the pending motion to dismiss, NTEU filed a Rule 41(a)(1)(A)(i) notice of voluntary dismissal, and the court dismissed the case without prejudice (ECF 17).
Summary Authors
Karma Karira (2/25/2025)
Brian Chen (8/4/2025)
Clay Canady (10/27/2025)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69624412/parties/national-treasury-employees-union-v-vought/
Leon, Richard J. (District of Columbia)
Dunn, Lindsay (District of Columbia)
Giles, Allison Conrey (District of Columbia)
Shah, Paras N. (District of Columbia)
Holt, Samuel (District of Columbia)
See docket on RECAP: https://www.courtlistener.com/docket/69624412/national-treasury-employees-union-v-vought/
Last updated Dec. 17, 2025, 4:18 a.m.
State / Territory:
Case Type(s):
Presidential/Gubernatorial Authority
Special Collection(s):
Trump Administration 2.0: Challenges to the Government
Key Dates
Filing Date: Feb. 9, 2025
Closing Date: Sept. 19, 2025
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Plaintiff National Treasury Employees Union (NTEU) is a labor union that represents federal government employees in 37 agencies and departments in grievances and litigation.
Plaintiff Type(s):
Non-profit NON-religious organization
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Consumer Financial Protection Bureau (- United States (national) -), Federal
Defendant Type(s):
Case Details
Causes of Action:
Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.
Constitutional Clause(s):
Other Dockets:
District of District of Columbia 1:25-cv-00380
Available Documents:
Outcome
Prevailing Party: None Yet / None
Relief Granted:
Source of Relief:
Form of Settlement:
Issues
Presidential/Gubernatorial Authority: