Case: Open Technology Fund v. Lake

1:25-cv-00840 | U.S. District Court for the District of District of Columbia

Filed Date: March 20, 2025

Case Ongoing

Clearinghouse coding complete

Case Summary

This case challenged the termination of congressionally appropriated grant funding to the Open Technology Fund (OTF), a nonprofit dedicated to promoting internet freedom. OTF filed suit in the United States District Court for the District of Columbia against the Senior Advisor to the Acting CEO of the U.S. Agency for Global Media (USAGM); the Acting CEO of USAGM; USAGM itself; and the Office of Management and Budget (OMB). The case was assigned to Judge Royce C. Lamberth. OTF sought declaratory…

This case challenged the termination of congressionally appropriated grant funding to the Open Technology Fund (OTF), a nonprofit dedicated to promoting internet freedom. OTF filed suit in the United States District Court for the District of Columbia against the Senior Advisor to the Acting CEO of the U.S. Agency for Global Media (USAGM); the Acting CEO of USAGM; USAGM itself; and the Office of Management and Budget (OMB). The case was assigned to Judge Royce C. Lamberth. OTF sought declaratory and injunctive relief, arguing that the defendants unlawfully withheld congressionally mandated funding in violation of statutory and constitutional provisions.

OTF’s mission, as defined by Congress, is to develop and maintain technologies that counter censorship and surveillance, ensuring free and secure access to the internet for individuals worldwide. USAGM, an independent federal agency, is legally required to provide OTF with annual grant funding, which Congress specifically earmarked for internet freedom programs. In 2024, Congress allocated at least $43.5 million for such initiatives, with continued funding authorized into fiscal year 2025. On February 26, 2025, OTF submitted a standard request for a $655,508 drawdown from its grant to fund March operations. However, USAGM failed to disburse the funds, deviating from its usual seven-day processing timeline.

On March 14, 2025, President Trump issued an executive order titled Continuing the Reduction of the Federal Bureaucracy (Executive Order). This order directed multiple federal agencies, including USAGM, to scale back their operations and eliminate non-statutory programs. The next day, the Senior Advisor to the Acting CEO of the U.S. Agency for Global Media (USAGM) issued a letter terminating all of USAGM’s grant agreements with OTF, citing shifting agency priorities. OTF contended that this action ignored explicit congressional mandates and amounted to an unconstitutional impoundment of funds.

OTF filed a complaint on March 20, 2025, arguing the defendants violated the Administrative Procedure Act (APA) because they acted arbitrarily, capriciously, and contrary to statutory and constitutional law. The lawsuit also alleged violations of the Separation of Powers, Appropriations Clause, Spending Clause, Presentment, and Take Care Clause of the U.S. Constitution, asserting that the executive branch could not override Congress’s explicit funding decisions. Additionally, OTF sought a writ of mandamus to compel USAGM to release the withheld funds and a declaration that the grant termination was unlawful. The plaintiff also sought a permanent injunction barring the defendants from impounding the OTF’s congressionally appropriated funds. 

Given the immediate threat to its operations, OTF also requested an emergency temporary restraining order and a preliminary injunction on the same day they filed their complaint. They argued a TRO would prevent irreparable harm, including the shutdown of key programs, contract terminations, and the loss of funding for internet freedom technologies relied upon by millions worldwide. Defendants filed their opposition to the TRO order on March 24, 2025.

On March 27, 2025, defendants filed a notice to the court that they withdrew the grant termination. In lifht of their withdrawal, the Court deferred to decide on the TRO request conditioned upon the requirement that defendants file daily status reports, starting April 1, 2025, for seven days or until the $655,508 owed to plaintiffs was dispersed in their account. 

Summary Authors

Jillian Snyman (3/26/2025)

Related Cases

Radio Free Asia v. United States of America, District of District of Columbia (2025)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69765042/parties/open-technology-fund-v-lake/


Judge(s)

Lamberth, Royce C. (District of Columbia)

Attorney for Plaintiff

Amberson, Sophia Elizabeth (District of Columbia)

Daugherty, Patrick O. (District of Columbia)

Quihuis, Liberty (District of Columbia)

Attorney for Defendant

Heiman, Julia Alexandra (District of Columbia)

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Documents in the Clearinghouse

Document
1

1:25-cv-00840

Complaint for Declaratory and Injunctive Relief

March 20, 2025

March 20, 2025

Complaint
4

1:25-cv-00840

Plaintiff's Motion for Temporary Restraining Order

March 20, 2025

March 20, 2025

Pleading / Motion / Brief
7

1:25-cv-00840

Defendants' Opposition to Plaintiff's Motion for a Temporary Restraining Order

March 24, 2025

March 24, 2025

Pleading / Motion / Brief
16

1:25-cv-00840

Order

March 31, 2025

March 31, 2025

Order/Opinion
19

1:25-cv-00840

Notice of Withdrawal of Motion

April 3, 2025

April 3, 2025

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/69765042/open-technology-fund-v-lake/

Last updated April 22, 2025, 12:11 p.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against Kari Lake, Victor Morales, UNITED STATES AGENCY FOR GLOBAL MEDIA, UNITED STATES OFFICE OF MANAGEMENT AND BUDGET ( Filing fee $ 405 receipt number ADCDC-11556988) filed by OPEN TECHNOLOGY FUND. (Attachments: # 1 Civil Cover Sheet, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons, # 6 Summons, # 7 Summons)(Daugherty, Patrick) (Entered: 03/20/2025)

1 Civil Cover Sheet

View on PACER

2 Summons

View on PACER

3 Summons

View on PACER

4 Summons

View on PACER

5 Summons

View on PACER

6 Summons

View on PACER

7 Summons

View on PACER

March 20, 2025

March 20, 2025

Clearinghouse
2

NOTICE OF RELATED CASE by OPEN TECHNOLOGY FUND. Case related to Case No. 1:25-cv-799. (Daugherty, Patrick) (Entered: 03/20/2025)

March 20, 2025

March 20, 2025

PACER
3

LCvR 26.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by OPEN TECHNOLOGY FUND (Daugherty, Patrick) (Entered: 03/20/2025)

March 20, 2025

March 20, 2025

PACER
4

MOTION for Temporary Restraining Order by OPEN TECHNOLOGY FUND. (Attachments: # 1 Memorandum in Support, # 2 Declaration of Laura Cunningham, # 3 Exhibit A, # 4 Exhibit B, # 5 Text of Proposed Order)(Daugherty, Patrick) (Entered: 03/20/2025)

March 20, 2025

March 20, 2025

Clearinghouse

Case Assigned to Judge Royce C. Lamberth. (zjd)

March 21, 2025

March 21, 2025

PACER

Case Assigned/Reassigned

March 21, 2025

March 21, 2025

PACER

.Order AND ~Util - Set/Reset Deadlines

March 21, 2025

March 21, 2025

PACER
5

SUMMONS (6) Issued Electronically as to All Defendants, U.S. Attorney, and U.S. Attorney General. (Attachment: # 1 Notice and Consent) (zjd) (Main Document 5 replaced on 3/21/2025) (zdp). (Entered: 03/21/2025)

March 21, 2025

March 21, 2025

PACER

MINUTE ORDER: It is hereby ORDERED that the defendants shall file their opposition to the plaintiff's Motion 4 for a Temporary Restraining Order on or before March 24, 2025. Signed by Judge Royce C. Lamberth on 03/21/2025. (lcrcl2)

March 21, 2025

March 21, 2025

PACER
6

NOTICE of Appearance by Julia Alexandra Heiman on behalf of KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA, UNITED STATES OFFICE OF MANAGEMENT AND BUDGET (Heiman, Julia) (Entered: 03/24/2025)

March 24, 2025

March 24, 2025

PACER
7

RESPONSE re 4 MOTION for Temporary Restraining Order filed by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA, UNITED STATES OFFICE OF MANAGEMENT AND BUDGET. (Attachments: # 1 Text of Proposed Order)(Heiman, Julia) (Entered: 03/24/2025)

March 24, 2025

March 24, 2025

Clearinghouse
8

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Sophia E. Amberson, Filing fee $ 100, receipt number ADCDC-11565072. Fee Status: Fee Paid. by OPEN TECHNOLOGY FUND. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Daugherty, Patrick) (Entered: 03/25/2025)

March 25, 2025

March 25, 2025

PACER
9

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Liberty Quihuis, Filing fee $ 100, receipt number ADCDC-11565167. Fee Status: Fee Paid. by OPEN TECHNOLOGY FUND. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Daugherty, Patrick) (Entered: 03/25/2025)

March 25, 2025

March 25, 2025

PACER

.Order

March 26, 2025

March 26, 2025

PACER

Notice of Hearing

March 26, 2025

March 26, 2025

PACER

NOTICE of Hearing: Motion Hearing, re: 4 Motion for Temporary Restraining Order is set for 3/27/2025 at 10:00 AM in Courtroom 15 (In Person) before Judge Royce C. Lamberth. (smc)

March 26, 2025

March 26, 2025

PACER

Order on Motion for Leave to Appear Pro Hac Vice

March 26, 2025

March 26, 2025

PACER

MINUTE ORDER: The court will provide access for the public to telephonically attend the hearing scheduled for March 27, 2025, at 10:00 AM. The hearing can be accessed by dialing the Toll-Free Number: 833-990-9400 (Meeting ID: 720718696). It is hereby ORDERED that the attendees using the public access telephone line shall adhere to the following: persons remotely accessing court proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting any court proceedings (including those held by telephone or videoconference). Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the presiding Judge. Signed by Judge Royce C. Lamberth on 3/26/2025. (smc)

March 26, 2025

March 26, 2025

PACER
10

REPLY to opposition to motion re 4 Motion for TRO filed by OPEN TECHNOLOGY FUND. (Attachments: # 1 Declaration (Second) Cunningham, # 2 Exhibit C)(Daugherty, Patrick) (Entered: 03/26/2025)

1 Declaration (Second) Cunningham

View on RECAP

2 Exhibit C

View on RECAP

March 26, 2025

March 26, 2025

RECAP

MINUTE ORDER: Upon consideration of the Motion 8 for Leave to Appear Pro Hac Vice, it is hereby ORDERED that the Motion is GRANTED. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a) Click for instructions. Signed by Judge Royce C. Lamberth on 03/26/2025. (lcrcl2)

March 26, 2025

March 26, 2025

PACER

MINUTE ORDER: Upon consideration of the Motion 9 for Leave to Appear Pro Hac Vice, it is hereby ORDERED that the Motion is GRANTED. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a) Click for instructions. Signed by Judge Royce C. Lamberth on 03/26/2025. (lcrcl2)

March 26, 2025

March 26, 2025

PACER
11

NOTICE of Appearance by Sophia Elizabeth Amberson on behalf of OPEN TECHNOLOGY FUND (Amberson, Sophia) (Entered: 03/26/2025)

March 26, 2025

March 26, 2025

PACER
12

NOTICE of Appearance by Abigail Stout on behalf of All Defendants (Stout, Abigail) (Main Document 12 replaced on 3/27/2025) (zdp). (Entered: 03/27/2025)

March 27, 2025

March 27, 2025

PACER

Status Conference

March 27, 2025

March 27, 2025

PACER

Notice of Hearing

March 27, 2025

March 27, 2025

PACER
13

NOTICE OF WITHDRAWAL OF GRANT TERMINATION by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA, UNITED STATES OFFICE OF MANAGEMENT AND BUDGET (Stout, Abigail) (Entered: 03/27/2025)

March 27, 2025

March 27, 2025

RECAP

Minute Entry for proceedings held before Judge Royce C. Lamberth: Case originally called for Motion Hearing but not held. Status Conference held on 3/27/2025. Parties informed Court they are reaching agreement. Court Reporter: Lisa Moreira. (smc)

March 27, 2025

March 27, 2025

PACER
14

NOTICE of Appearance by Liberty Quihuis on behalf of OPEN TECHNOLOGY FUND (Quihuis, Liberty) (Entered: 03/27/2025)

March 27, 2025

March 27, 2025

PACER

NOTICE of Hearing: Motion Hearing set for 3/31/2025 at 2:00 PM via ZOOM before Judge Royce C. Lamberth. (smc)

March 27, 2025

March 27, 2025

PACER
15

NOTICE Defendants' Supplemental Notice by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA, UNITED STATES OFFICE OF MANAGEMENT AND BUDGET (Heiman, Julia) (Entered: 03/27/2025)

March 27, 2025

March 27, 2025

RECAP

Motion Hearing

March 31, 2025

March 31, 2025

PACER

Minute Entry for Video Motion Hearing held on 3/31/2025 before Judge Royce C. Lamberth: re 4 MOTION for Temporary Restraining Order . Oral arguments heard and TAKEN UNDER ADVISEMENT. Court Reporter: Sara Wick. (smc)

March 31, 2025

March 31, 2025

PACER
16

ORDER: The Court will defer ruling on the Motion 4 for a Temporary Restraining Order at this time. Upon consideration of the plaintiff's Motion 4 for a Temporary Restraining Order, the responses and replies thereto, the parties' representations at the hearings held on March 27, 2025 and March 31, 2025, and the entire record herein, it is hereby ORDERED that the defendants shall file daily status updates, beginning on April 1, 2025, and continuing for seven days or until the $655,508 associated with OTF's March drawdown request is disbursed to the plaintiff, or until the Court orders otherwise. The defendants are advised that, if the status updates are found to be lacking in sufficient detail or fail to demonstrate adequate progress, the Court will proceed to rule on the Motion for a Temporary Restraining Order. Signed by Judge Royce C. Lamberth on 03/31/2025. (lcrcl2) (Entered: 03/31/2025)

March 31, 2025

March 31, 2025

Clearinghouse
17

STATUS REPORT by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA, UNITED STATES OFFICE OF MANAGEMENT AND BUDGET. (Heiman, Julia) (Entered: 04/01/2025)

April 1, 2025

April 1, 2025

RECAP
18

STATUS REPORT by KARI LAKE, VICTOR MORALES, UNITED STATES AGENCY FOR GLOBAL MEDIA, UNITED STATES OFFICE OF MANAGEMENT AND BUDGET. (Heiman, Julia) (Entered: 04/02/2025)

April 2, 2025

April 2, 2025

RECAP
19

NOTICE OF WITHDRAWAL OF MOTION by OPEN TECHNOLOGY FUND re 4 MOTION for Temporary Restraining Order (Daugherty, Patrick) (Entered: 04/03/2025)

April 3, 2025

April 3, 2025

Clearinghouse
20

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 3/24/2025., RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 3/24/2025. ( Answer due for ALL FEDERAL DEFENDANTS by 5/23/2025.), RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. All Defendants (Attachments: # 1 Exhibit A)(Daugherty, Patrick) (Entered: 04/07/2025)

April 7, 2025

April 7, 2025

PACER

Case Details

State / Territory: District of Columbia

Case Type(s):

Presidential/Gubernatorial Authority

Special Collection(s):

Trump Administration 2.0: Challenges to the Government

Trump Administration 2.0: Challenges to the Government (Spending Freezes/Cuts)

Key Dates

Filing Date: March 20, 2025

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

Open Technology Fund is a private, independent, not-for-profit 501(c)(3) organization dedicated to advancing global internet freedom. They support the research, development, implementation, and maintenance of tools and technologies focused on counteracting repressive censorship and surveillance, enabling citizens worldwide to reliably access news and information, and to exercise their fundamental human rights online.

Plaintiff Type(s):

Non-profit NON-religious organization

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

U.S. Agency for Global Media, Federal

Office of Management and Budget, Federal

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

Ex Parte Young (Federal) or Bivens

Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.

Declaratory Judgment Act, 28 U.S.C. § 2201

Ex parte Young (federal or state officials)

Constitutional Clause(s):

Spending/Appropriations Clauses

Separation of Powers

Presentment Clause

Take Care Clause

Available Documents:

Trial Court Docket

Complaint (any)

Outcome

Prevailing Party: None Yet / None

Nature of Relief:

None yet

Source of Relief:

None yet

Issues

General/Misc.:

Funding

Presidential/Gubernatorial Authority:

Impoundment (mandatory spending)