Case: Grundmann v. Trump
1:25-cv-00425 | U.S. District Court for the District of District of Columbia
Filed Date: Feb. 13, 2025
Closed Date: Feb. 4, 2026
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Case Summary
This case challenged President Trump's removal of an individual from her position at the Federal Labor Relations Authority (FLRA). The plaintiff here was Chair of the FLRA, appointed to a five-year term by President Biden and confirmed by the U.S. Senate in May 2022. On February 10, 2025, she received a one-sentence email from the Trump Administration stating that her position at the FLRA was “terminated, effective immediately,” with no context or reasoning for the firing. Her termination occurred within the broader context of the Trump Administration’s actions to shrink the federal workforce.
On February 13, 2025, the ex-Chair filed a lawsuit in the U.S. District Court for the District of Columbia against the President of the United States and the chairman of the FLRA. Represented by the State Democracy Defenders Fund, she sought a declaration that her removal was unlawful and an injunction, ordering her reinstatement as a member of the Board and preventing the administration from obstructing her duties. She claimed that her removal was a violation of the Federal Service Labor-Management Relations Statute, specifically 5 U.S.C. § 7104. This statute states that members of the FLRA may only be removed upon “notice and hearing” and only for “inefficiency, neglect of duty, or malfeasance in office.” Noting that none of these reasons were mentioned in the termination email, the plaintiff here contended that the firing was unlawful and a “clear attempt” to contravene Congress’s statutory scheme. District Judge Sparkle L. Sooknanan was assigned to this case on February 14, 2025.
Also on February 14, 2025, the plaintiff filed a motion for a preliminary injunction and summary judgment. She requested preliminary relief due to the irreparable nature of the injury that an injunction would prevent. Explaining that there was no genuine issue of material fact, along with a clear violation of law causing the plaintiff to suffer irreparable injury, she sought expedited consideration of the motion. On February 17, 2025, based on a Joint Status Report filed by the parties, the Court set a briefing schedule with a hearing, if necessary, scheduled for March 7, 2025. The government filed a cross-motion for summary judgment on February 25th.
Following the March 7 hearing, the Court granted the plaintiff's motion for summary judgment and denied the defendants’ cross-motion. In the order, filed on March 12, 2025, Judge Sooknanan emphasized the need for checks and balances and the importance of abiding by longstanding Supreme Court precedent. She explained that the government's removal of the plaintiff from her position was in "clear contravention" of the Federal Service Labor-Management Relations Statute. She further held that the statute is constitutional under Congress's Article I authority. 770 F.Supp.3d 166.
As a result of this order, the plaintiff will continue to serve as a member of the FLRA until her term expires or unless she is removed earlier for inefficiency, neglect of duty, or malfeasance. The defendants are enjoined from removing her without cause or impeding her ability to fulfill her duties in any way. On May 27, the defendants asked the court to stay its order while the defendants appealed. The court rejected the request on June 13. 786 F.Supp.3d 188.
On May 8, 2025, the defendants appealed the Court's grant of summary judgment to the U.S. Court of Appeals for the District of Columbia Circuit, asking the court for an immediate administrative stay and a stay pending appeal. On June 18, the court of appeals issued a per curiam order administratively staying the district court's order. Without elaborating on its reasoning, the court stayed the order pending further direction and instructed the parties to complete briefing on the defendants' motion for a stay pending appeal by June 27. The court also denied a motion for rehearing en banc on July 16, 2025. 2025 WL 1995785.
The following states filed an amicus brief on behalf of the government: Florida, Alabama, Arkansas, Arizona House of Reps., Arizona Senate, Georgia, Idaho, Iowa, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Montana, Nebraska, North Dakota, Oklahoma, South Carolina, South Dakota, Tennessee, Texas, and West Virginia.
On October 29, 2025, the D.C. Circuit removed the case from its oral argument calendar and held the appeal in abeyance pending the Supreme Court's disposition of Trump v. Slaughter. On January 21, 2026, the plaintiff moved to dismiss the appeal as moot after her successor, Charles Arrington, was appointed and confirmed to the FLRA, ending her statutory holdover service. She also requested that the D.C. Circuit vacate the district court's judgment and remand with instructions to dismiss the case. On February 4, 2026, the D.C. Circuit granted the motion, vacated the district court's March 12, 2025 opinion and order, and remanded with instructions to dismiss the case with prejudice. On February 11, 2026, the district court dismissed the case with prejudice pursuant to the D.C. Circuit's mandate. On June 29, 2026, the Supreme Court decided Trump v. Slaughter, overruling Humphrey's Executor v. United States and holding that statutory for-cause removal protections for members of independent agencies exercising executive power unconstitutionally restrict the President's Article II removal authority. Although this case had already been dismissed as moot, Slaughter abrogated the district court's reasoning that the Federal Service Labor-Management Relations Statute's for-cause removal protections were constitutional.
Summary Authors
Benjamin Glicksman (7/10/2026)
Aanvi Jhaveri (5/8/2025)
Jeremiah Price (6/24/2025)
Jinan Abufarha (10/26/2025)
Allison Opheim (2/10/2026)
Related Cases
Wilcox v. Trump, District of District of Columbia (2025)
Harris v. Bessent, District of District of Columbia (2025)
People
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69637796/parties/grundmann-v-trump/
Attorney, Pooja Chaudhuri, (District of Columbia)
Attorney, Mark Reiling (District of Columbia)
Attorney, Michael S. (District of Columbia)
Attorney, Daniel J. (District of Columbia)
Attorney, Darin Dalmat, (District of Columbia)
Attorney, Darin Dalmat, (District of Columbia)
Attorney, Jeffrey Paul (District of Columbia)
Counsel, Elizabeth Wydra, (District of Columbia)
Esquire, Kris W. (District of Columbia)
Frazelle, Brian Rene (District of Columbia)
Ginsburg, Matthew James (District of Columbia)
Documents in the Clearinghouse
Docket
See docket on RECAP: https://www.courtlistener.com/docket/69637796/grundmann-v-trump/
Last updated Sept. 8, 2026, 4:09 a.m.
Docket for: GRUNDMANN v. TRUMP
Case Details
State / Territory:
Case Type(s):
Presidential/Gubernatorial Authority
Special Collection(s):
Trump Administration 2.0: Challenges to the Government
Key Dates
Filing Date: Feb. 13, 2025
Closing Date: Feb. 4, 2026
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Member of the Federal Labor Relations Authority (FLRA) who was terminated.
Plaintiff Type(s):
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Federal
Federal Labor Relations Authority
President Donald Trump
Defendant Type(s):
Case Details
Causes of Action:
Federal Service Labor-Management Relations Statute, 5 U.S.C. §7101
Other Dockets:
District of District of Columbia 1:25-cv-00425
U.S. Court of Appeals for the District of Columbia Circuit 25-05165
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: None Yet / None
Relief Sought:
Relief Granted:
Source of Relief:
Order Duration: 2025 - 2026
Issues
General/Misc.:
Presidential/Gubernatorial Authority:
Case Summary of Grundmann v. Trump, Civil Rights Litig. Clearinghouse, https://clearinghouse.net/case/46125/ (last updated 2/10/2026).