Case: Project on Government Oversight, Inc. v. Trump

1:25-cv-00527 | U.S. District Court for the District of District of Columbia

Filed Date: Feb. 21, 2025

Case Ongoing

Clearinghouse coding complete

Case Summary

This case challenges the Trump administration’s recordkeeping practices related to the Department of Government Efficiency (DOGE). On February 21, 2025, the nonprofit watchdog organization Project on Government Oversight (POGO) filed this lawsuit in the U.S. District Court for the District of Columbia against President Donald Trump, DOGE, the U.S. DOGE Service (USDS), its Temporary Organization (USDSTO), and the USDS Acting Administrator. POGO alleged that these entities—though styled as presid…

This case challenges the Trump administration’s recordkeeping practices related to the Department of Government Efficiency (DOGE). On February 21, 2025, the nonprofit watchdog organization Project on Government Oversight (POGO) filed this lawsuit in the U.S. District Court for the District of Columbia against President Donald Trump, DOGE, the U.S. DOGE Service (USDS), its Temporary Organization (USDSTO), and the USDS Acting Administrator. POGO alleged that these entities—though styled as presidential—are in fact federal agencies subject to the Federal Records Act (FRA) and the Freedom of Information Act (FOIA), and that they have unlawfully designated their records as presidential in order to avoid legal transparency obligations.

Represented by private counsel, the plaintiff sought declaratory, injunctive, and mandamus relief. The plaintiff asserted that DOGE has defied federal recordkeeping laws by refusing to create or preserve public records, operating without a FRA-compliant records policy, and asserting that its files are governed solely by the Presidential Records Act (PRA).

The case was assigned to Chief Judge James E. Boasberg.

On March 24, 2025, POGO moved for a preliminary injunction (PI) requiring the defendants to preserve all records during the litigation. Defendants opposed, arguing that DOGE is not a federal agency subject to the FRA but rather an advisory entity governed by the PRA, and that POGO lacked standing because it had not been denied a FOIA request. On April 23, POGO filed a reply in support of its PI motion and cited its recently submitted FOIA request, which USDS had declined to process on the grounds that PRA, not FOIA, applied.

POGO amended its complaint on May 9, 2025, and renewed its motion for preliminary injunction on May 15, asserting an ongoing risk of unlawful destruction of records and that USDS exercises substantial independent authority inconsistent with a mere advisory role.

On June 17, 2025, the district court denied the renewed preliminary injunction, finding that POGO had failed to show a likelihood of irreparable harm. The court emphasized that USDS had adopted a formal records retention policy under the PRA and was already subject to multiple preservation orders in other FOIA litigation, which mitigated any showing of imminent harm.

The case remains ongoing.

Summary Authors

Madilynn O'Hara (3/4/2025)

Brian Chen (6/20/2025)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69661712/parties/project-on-government-oversight-inc-v-trump/


Judge(s)

Boasberg, James Emanuel (District of Columbia)

Attorney for Plaintiff

Weismann, Anne L. (District of Columbia)

Attorney for Defendant

Shapiro, Elizabeth J. (District of Columbia)

Wyer, Kathryn L. (District of Columbia)

show all people

Documents in the Clearinghouse

Document
1

1:25-cv-00527

Complaint

Project on Government Oversight v. Trump

Feb. 21, 2025

Feb. 21, 2025

Complaint
11

1:25-cv-00527

Plaintiff's Motion for a Preliminary Injunction

March 24, 2025

March 24, 2025

Pleading / Motion / Brief
12

1:25-cv-00527

Defendants' Memorandum of Points and Authorities in Opposition to Plaintiff's Motion for a Preliminary Injuntion

April 7, 2025

April 7, 2025

Pleading / Motion / Brief
14

1:25-cv-00527

Reply in Support of Plaintiff's Motion for a Preliminary Injunction

April 23, 2025

April 23, 2025

Pleading / Motion / Brief
16

1:25-cv-00527

First Amended Complaint

May 9, 2025

May 9, 2025

Complaint
17

1:25-cv-00527

Plaintiff's Renewed Motion for a Preliminary Injunction

May 15, 2025

May 15, 2025

Pleading / Motion / Brief
19

1:25-cv-00527

Defendants' Memorandum of Points and Authorities in Opposition to Plaintiff's Renewed Motion for a Preliminary Injunction

May 28, 2025

May 28, 2025

Pleading / Motion / Brief
23

1:25-cv-00527

Memorandum Opinion

June 17, 2025

June 17, 2025

Order/Opinion

2025 WL 1707690

22

1:25-cv-00527

Order

June 17, 2025

June 17, 2025

Order/Opinion

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/69661712/project-on-government-oversight-inc-v-trump/

Last updated July 12, 2025, 2:23 p.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against ADMINISTRATOR, U.S. DOGE SERVICE TEMPORARY ORGANIZATION, DONALD J. TRUMP, U.S..DOGE SERVICE TEMPORARY ORGANIZATION, U.S. DEPARTMENT OF GOVERNMENT EFFICIENCY, U.S. DOGE SERVICE ( Filing fee $ 405 receipt number ADCDC-11495912) filed by PROJECT ON GOVERNMENT OVERSIGHT, INC.. (Attachments: # 1 Summons U. Attorney, # 2 Summons Attorney General, # 3 Summons Administrator, DOGE Service Temporary Service, # 4 Summons U.S. DOGE Service Temporary Service, # 5 Summons President of the United States, # 6 Summons U.S Dep't of Government Efficiency, # 7 Summons U.S. DOGE Service, # 8 Civil Cover Sheet)(Weismann, Anne) (Entered: 02/21/2025)

1 Summons U. Attorney

View on PACER

2 Summons Attorney General

View on PACER

3 Summons Administrator, DOGE Service Temporary Service

View on PACER

4 Summons U.S. DOGE Service Temporary Service

View on PACER

5 Summons President of the United States

View on PACER

6 Summons U.S Dep't of Government Efficiency

View on PACER

7 Summons U.S. DOGE Service

View on PACER

8 Civil Cover Sheet

View on PACER

Feb. 21, 2025

Feb. 21, 2025

Clearinghouse

Case Assigned/Reassigned

Feb. 21, 2025

Feb. 21, 2025

PACER
2

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by PROJECT ON GOVERNMENT OVERSIGHT, INC. (Weismann, Anne) (Entered: 02/21/2025)

Feb. 21, 2025

Feb. 21, 2025

PACER

Case Assigned to Chief Judge James E. Boasberg. (zmtm)

Feb. 21, 2025

Feb. 21, 2025

PACER
3

SUMMONS (7) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zmtm) (Entered: 02/21/2025)

1 Notice and Consent

View on PACER

Feb. 21, 2025

Feb. 21, 2025

PACER
4

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 2/24/2025. Answer due for ALL FEDERAL DEFENDANTS by 4/25/2025. (Weismann, Anne) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

PACER
5

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 2/24/2025. (Weismann, Anne) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

PACER
6

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. ADMINISTRATOR, U.S. DOGE SERVICE TEMPORARY ORGANIZATION served on 2/28/2025 (Weismann, Anne) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

PACER
7

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S..DOGE SERVICE TEMPORARY ORGANIZATION served on 2/28/2025 (Weismann, Anne) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

PACER
8

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. DONALD J. TRUMP served on 2/28/2025 (Weismann, Anne) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

PACER
9

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. DEPARTMENT OF GOVERNMENT EFFICIENCY served on 2/28/2025 (Weismann, Anne) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

PACER
10

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. U.S. DOGE SERVICE served on 2/28/2025 (Weismann, Anne) (Entered: 03/11/2025)

March 11, 2025

March 11, 2025

RECAP
11

MOTION for Preliminary Injunction by PROJECT ON GOVERNMENT OVERSIGHT, INC.. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A-C, # 3 Text of Proposed Order)(Weismann, Anne) (Entered: 03/24/2025)

1

View on RECAP

2

View on RECAP

March 24, 2025

March 24, 2025

Clearinghouse

.Order AND ~Util - Set/Reset Deadlines AND ~Util - Set/Reset Hearings

March 27, 2025

March 27, 2025

PACER

MINUTE ORDER: The Court ORDERS that: 1) Defendants shall file their Opposition to Plaintiff's 11 Motion for a Preliminary Injunction by April 7, 2025; 2) Plaintiff shall file its Reply by April 23, 2025; and 3) The parties shall appear for a hearing on the Motion via Zoom on May 2, 2025, at 11:30 a.m. So ORDERED by Chief Judge James E. Boasberg on March 27, 2025. (lcjeb4)

March 27, 2025

March 27, 2025

PACER
12

Memorandum in opposition to re 11 Motion for Preliminary Injunction filed by ADMINISTRATOR, U.S. DOGE SERVICE TEMPORARY ORGANIZATION, DONALD J. TRUMP, U.S..DOGE SERVICE TEMPORARY ORGANIZATION, U.S. DEPARTMENT OF GOVERNMENT EFFICIENCY, U.S. DOGE SERVICE. (Attachments: # 1 Exhibit A - USDS Records Retention Policy, # 2 Text of Proposed Order)(Wyer, Kathryn) (Entered: 04/07/2025)

April 7, 2025

April 7, 2025

Clearinghouse
13

Consent MOTION for Extension of Time to File Answer re 1 Complaint,, or Otherwise Respond by ADMINISTRATOR, U.S. DOGE SERVICE TEMPORARY ORGANIZATION, DONALD J. TRUMP, U.S..DOGE SERVICE TEMPORARY ORGANIZATION, U.S. DEPARTMENT OF GOVERNMENT EFFICIENCY, U.S. DOGE SERVICE. (Attachments: # 1 Text of Proposed Order)(Wyer, Kathryn) (Entered: 04/09/2025)

1 Text of Proposed Order

View on PACER

April 9, 2025

April 9, 2025

PACER

Order on Motion for Extension of Time to Answer

April 9, 2025

April 9, 2025

PACER

MINUTE ORDER: The Court ORDERS that: 1) The Consent 13 Motion for Extension of Time is GRANTED; and 2) Defendants shall file their Answer or otherwise respond to Plaintiff's Complaint by thirty days after the Court issues a ruling on Plaintiff's Motion for a Preliminary Injunction. So ORDERED by Chief Judge James E. Boasberg on 4/9/2025. (lcjeb4)

April 9, 2025

April 9, 2025

PACER
14

REPLY to opposition to motion re 11 Motion for Preliminary Injunction filed by PROJECT ON GOVERNMENT OVERSIGHT, INC.. (Attachments: # 1 Exhibit A, B, C)(Weismann, Anne) (Entered: 04/23/2025)

1 Exhibit A, B, C

View on PACER

April 23, 2025

April 23, 2025

Clearinghouse

Minute Entry for proceedings held before Chief Judge James E. Boasberg: Preliminary Injunction Hearing held via Zoom on 5/2/2025.Oral argument heard; motion denied without prejudice for the reasons stated on the record. (Court Reporter Janice Dickman) (znbn)

May 2, 2025

May 2, 2025

PACER

MINUTE ORDER: As discussed in today's hearing, the Court ORDERS that Plaintiff's 11 Motion for Preliminary Injunction is DENIED WITHOUT PREJUDICE. So ORDERED by Chief Judge James E. Boasberg on May 2, 2025. (lcjeb3)

May 2, 2025

May 2, 2025

PACER
15

TRANSCRIPT OF PROCEEDINGS before Chief Judge James E. Boasberg held on May 2, 2025; Page Numbers: 1-16. Date of Issuance: May 7, 2025. Court Reporter: Janice Dickman, Telephone number: 202-354-3267, Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 5/28/2025. Redacted Transcript Deadline set for 6/7/2025. Release of Transcript Restriction set for 8/5/2025.(Dickman, Janice)

May 7, 2025

May 7, 2025

PACER
16

AMENDED COMPLAINT against All Defendants filed by PROJECT ON GOVERNMENT OVERSIGHT, INC..(Weismann, Anne) (Entered: 05/09/2025)

May 9, 2025

May 9, 2025

Clearinghouse
17

Second MOTION for Preliminary Injunction by PROJECT ON GOVERNMENT OVERSIGHT, INC.. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Weismann, Anne) (Entered: 05/15/2025)

1 Memorandum in Support

View on RECAP

2 Text of Proposed Order

View on RECAP

May 15, 2025

May 15, 2025

Clearinghouse

.Order AND ~Util - Set/Reset Deadlines/Hearings

May 19, 2025

May 19, 2025

PACER

MINUTE ORDER: The Court ORDERS that: 1) Defendants shall file their Opposition to Plaintiff's 17 Second Motion for a Preliminary Injunction by May 28, 2025; 2) Plaintiff shall file its Reply by June 4, 2025; and 3) The parties shall appear for a hearing on the Motion via Zoom on June 5, 2025, at 11:00 a.m. So ORDERED by Chief Judge James E. Boasberg on May 19, 2025. (lcjeb3)

May 19, 2025

May 19, 2025

PACER

.Order

May 19, 2025

May 19, 2025

PACER
18

Consent MOTION for Extension of Time to File Answer re 16 Amended Complaint or Otherwise Respond by ADMINISTRATOR, U.S. DOGE SERVICE TEMPORARY ORGANIZATION, AMY GLEASON, DONALD J. TRUMP, U.S..DOGE SERVICE TEMPORARY ORGANIZATION, U.S. DEPARTMENT OF GOVERNMENT EFFICIENCY, U.S. DOGE SERVICE. (Attachments: # 1 Text of Proposed Order)(Wyer, Kathryn) (Entered: 05/19/2025)

1 Text of Proposed Order

View on RECAP

May 19, 2025

May 19, 2025

RECAP

MINUTE ORDER: The Court ORDERS that: 1) The Consent 18 Motion for Extension of Time is GRANTED; and 2) Defendants shall file their Answer or otherwise respond to Plaintiff's Complaint by 30 days after the Court's ruling on Plaintiff's Second Motion for Preliminary Injunction. So ORDERED by Chief Judge James E. Boasberg on 5/19/2025. (lcjeb4)

May 19, 2025

May 19, 2025

PACER
19

Memorandum in opposition to re 17 Second MOTION for Preliminary Injunction filed by ADMINISTRATOR, U.S. DOGE SERVICE TEMPORARY ORGANIZATION, AMY GLEASON, DONALD J. TRUMP, U.S..DOGE SERVICE TEMPORARY ORGANIZATION, U.S. DEPARTMENT OF GOVERNMENT EFFICIENCY, U.S. DOGE SERVICE. (Attachments: # 1 Text of Proposed Order)(Wyer, Kathryn) (Entered: 05/28/2025)

1 Text of Proposed Order

View on RECAP

May 28, 2025

May 28, 2025

Clearinghouse
20

REPLY to opposition to motion re 17 Motion for Preliminary Injunction filed by PROJECT ON GOVERNMENT OVERSIGHT, INC.. (Weismann, Anne) (Entered: 06/04/2025)

June 4, 2025

June 4, 2025

PACER

.Order AND ~Util - Set/Reset Hearings

June 4, 2025

June 4, 2025

PACER

MINUTE ORDER: The Court ORDERS that the hearing on June 5, 2025, at 11:00 a.m. will proceed by videoconference for the parties and by telephone for members of the public. Toll free number: 833-990-9400. Meeting ID: 049550816. So ORDERED by Chief Judge James E. Boasberg on June 4, 2025. (lcjeb3)

June 4, 2025

June 4, 2025

PACER
21

NOTICE of Appearance by Elizabeth J. Shapiro on behalf of All Defendants (Shapiro, Elizabeth) (Entered: 06/05/2025)

June 5, 2025

June 5, 2025

PACER

Motion Hearing

June 5, 2025

June 5, 2025

PACER

Minute Entry for proceedings held before Chief Judge James E. Boasberg: Motion Hearing held via Zoom with the public access line connected on 6/5/2025 re 17 Second MOTION for Preliminary Injunction filed by PROJECT ON GOVERNMENT OVERSIGHT, INC.. Oral argument heard; motion taken under advisement. Order forthcoming. (Court Reporter Tammy Nestor) (znbn)

June 5, 2025

June 5, 2025

PACER
22

ORDER: The Court ORDERS that Plaintiff's 17 Motion for Preliminary Injunction is DENIED. SIGNED by Chief Judge James E. Boasberg on June 17, 2025. (lcjeb3) (Entered: 06/17/2025)

June 17, 2025

June 17, 2025

RECAP
23

MEMORANDUM OPINION re 22 Order on Motion for Preliminary Injunction. SIGNED by Chief Judge James E. Boasberg on June 17, 2025. (lcjeb3) (Entered: 06/17/2025)

June 17, 2025

June 17, 2025

RECAP

Case Details