Filed Date: March 24, 2025
Case Ongoing
Clearinghouse coding complete
Several lawsuits have been brought challenging the Trump administration’s attempt to dismantle the U.S. Department of Education. This case is one; the others can be found here.
On March 24, 2025, several school districts and labor organizations filed this lawsuit in the U.S. District Court for the District of Massachusetts, suing President Donald Trump, the U.S. Department of Education, and Secretary of Education Linda McMahon. The plaintiffs challenged the Trump administration's efforts to dismantle and eliminate the Department of Education, including a sweeping reduction in force and President Trump’s March 20, 2025 Executive Order, Improving Education Outcomes by Empowering Parents, States, and Communities. The complaint alleged that Defendants' actions violated the Separation of Powers, the Take Care Clause, and the Administrative Procedure Act ("APA"). This case was assigned to Judge Myong J. Joun.
The plaintiffs included two Massachusetts school districts—Somerville and Easthampton—as well as national and regional labor organizations representing educators and school staff: the American Federation of Teachers (AFT), AFT Massachusetts, AFSCME Council 93, the American Association of University Professors (AAUP), and the Service Employees International Union (SEIU). Represented by Democracy Forward, the plaintiffs argued that the Executive Order and mass terminations were a deliberate and unlawful attempt to eliminate a Cabinet-level agency that Congress created by statute in 1979. The plaintiffs maintained that only Congress has the authority to create or eliminate executive agencies, and that the President’s attempt to do so by Executive Order exceeded constitutional limits and violated the APA.
In their complaint, the plaintiffs made three claims: First, the plaintiffs asserted a Separation of Powers violation, arguing that the President cannot unilaterally abolish a federal agency that Congress established by law and continues to fund annually. Second, the plaintiffs invoked the Take Care Clause (U.S. Const. art. II, § 3), which requires the President to "take Care that the Laws be faithfully executed." They argued that the Executive’s plan to shutter the Department—despite clear statutory mandates to the contrary—was not an execution of the law but an attempt to circumvent or nullify it. Third, the plaintiffs challenged both the March 11, 2025, mass reduction in force (RIF) and the Executive Order as “final agency actions” that were arbitrary, capricious, and contrary to law under the APA.
In support of these claims, the complaint presented detailed factual evidence, including public statements from President Trump and Secretary McMahon confirming their intention to dismantle the Department. To demonstrate harm, the plaintiffs also provided district-level examples of how reductions in federal aid would stifle educational programming.
The plaintiffs sought multiple forms of relief: a preliminary and permanent injunction blocking the reduction in force and implementation of the Executive Order; a declaratory judgment finding the President’s actions unlawful and unconstitutional; and attorneys’ fees and costs.
On April 1, 2025, plaintiffs filed a motion for a preliminary injunction to block enforcement of President Trump’s March 20 Executive Order and the mass layoffs at the Department of Education. After briefing, a hearing was held on April 25. The court ruled in plaintiffs' favor on May 22, entering a preliminary injunction for the pendency of the litigation. 2025 WL 1463009. It enjoined the reduction in force, and the transfer of management of federal student loans and special education functions out of the Department. The court's order required the administration to reinstate federal employees whose employment was terminated as part of the reduction in force, and to "restore the Department to the status quo such that it is able to carry out its statutory functions."
On the same day, the court issued an order consolidating this case with State of New York v. McMahon, a similar challenge to the Department of Education’s reduction in force brought by 21 states. The court designated State of New York as the lead case, and the cases have proceeded together since. Defendants immediately appealed the consolidated cases to the U.S. Court of Appeals for the First Circuit on May 22, 2025. The defendants requested an immediate administrative stay and a stay pending appeal.
In the district court, the defendants also filed a motion to stay the preliminary injunction on May 22. On May 23, Judge Joun denied the motion. He found that, given the court's analysis in the order granting the preliminary injunction, the defendants would not suffer irreparable harm by maintaining the status quo, while staying the preliminary injunction would cause serious harm to the plaintiffs. 2025 WL 1478007.
On May 27, the Court of Appeals also denied the defendants' motion for an immediate administrative stay, 2025 WL 1503501, and on June 4, denied a stay pending appeal. 139 F.4th 63.
Looking first at whether the defendants had made a strong showing that they would prevail on the merits, the court found "no basis on which to conclude that the appellants have made a 'strong showing' that the District Court likely clearly erred in finding that the RIF made it effectively impossible for the Department to carry out its statutory obligations." The court also rejected the defendants' argument that the district court lacked jurisdiction because of the CSRA, since the court was "loath to attribute to Congress" the defendants' view that Congress "intended to bar every challenge to an unlawful effort by the Executive to shut down a statutorily created agency by summarily firing its employees en masse" through enactment of the CSRA. Therefore, the Court of Appeals found that the defendants had not made a strong showing that they would succeed on their argument that the plaintiffs lacked standing.
Looking at the merits, the court also held that the defendants had failed to make a "strong showing" of success, since their contentions "merely favorably characterize[d] the actions found to have been contrary to law and arbitrary and capricious" rather than explaining why the district court's ruling was erroneous. Finally, the court found that the RIF in this case sufficiently constituted a final agency action to support an action under the APA.
Turning to other concerns, the court also said that the defendants had failed to show that they would suffer an irreparable injury "by being required to carry out Congress's duly enacted statutes," or that the "public's interest lies in permitting a major federal department to be unlawfully disabled from performing its statutorily assigned functions." Therefore, the court denied the motion for a stay of the district court's injunction. 139 F.4th 63.
On June 6, the Government asked the Supreme Court to stay the district court's injunction for the duration of the litigation while the government appeals to the First Circuit and possibly the Supreme Court. In its application, the government argued that it was likely to succeed on the merits because the plaintiffs lacked standing, asserting that the district court "accepted a standing theory rife with speculation" about whether the Department would be able to fulfill its duties. The government also argued that the district court lacked subject matter jurisdiction over the dispute, since, while the district court admitted more limited reductions in force would have to be brought before the Merit Systems Protection Board, it found that more massive terminations granted it jurisdiction. Finally, the government argued that the district court lacked authority to order reinstatement as a remedy, and this case warranted the Court’s intervention because of the irreparable harm the Executive Branch would suffer if it were required to reinstate the employees.
The Supreme Court granted the government's request on July 14, staying the district court's preliminary injunction pending the resolution of the government's appeal in the First Circuit and any possible appeal to the Supreme Court. The Court did not explain its reasoning, but the decision came over the noted dissents of Justices Sotomayor, Kagan, and Jackson, who argued that "[w]hen the Executive publicly announces its intent to break the law, and then executes on that promise, it is the Judiciary’s duty to check that lawlessness, not expedite it." 145 S.Ct. 2643.
On August 8, 2025, the consolidated plaintiffs filed an unopposed motion in the district court, pursuant to Federal Rule of Civil Procedure 62.1, requesting that the district court issue an indicative ruling that it would vacate the preliminary injunction if the First Circuit were to remand the case. The motion was granted, and the First Circuit dismissed the consolidated appeal on September 15, 2025, remanding the matter back to the district court.
On September 25, 2025, the defendants moved to vacate the May 22, 2025 preliminary injunctions entered by this Court in both of the consolidated cases in light of the Supreme Court’s grant of a stay pending appeal, the Plaintiffs’ request for an indicative ruling from the district court that “[t]he Court would grant the Consolidated Plaintiffs’ motion to vacate the preliminary injunction if the United States Court of Appeals for the First Circuit were to remand,” and the First Circuit’s subsequent dismissal of appeal and remand.
The court granted the motion to vacate the preliminary injunction and the motion to stay the case in light of the federal government shutdown on October 1, 2025.
The case is ongoing.
Summary Authors
Karma Karira (5/7/2025)
Clearinghouse (5/22/2025)
Emma Vayda (6/5/2025)
Madena Mustafa (11/3/2025)
State of New York v. McMahon, District of Massachusetts (2025)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69778837/parties/somerville-public-schools-v-trump-font-colorred-bdo-not-docket-in/
Bardwell, Will (Massachusetts)
Bull, Gina (- United States (national) -)
Bruns, Michael Benjamin (Massachusetts)
Abelson, Dana A. (- United States (national) -)
Berman, Steve W. (- United States (national) -)
Bardwell, Will (Massachusetts)
Bull, Gina (- United States (national) -)
Carpenter, Caityn Babington (- United States (national) -)
Chin, Elleanor H. (- United States (national) -)
Choi, Lucia (- United States (national) -)
Coates, Spencer Wade (- United States (national) -)
Crawford, Haleigh (- United States (national) -)
Day, David Dana (- United States (national) -)
Dirks, Katherine B. (- United States (national) -)
Ehler, Karyn L. (- United States (national) -)
Fernandes, Kalikoonalani Diara (- United States (national) -)
Flynn, Elizabeth C. (- United States (national) -)
Garrett, Clinten N. (- United States (national) -)
Gibson, Charlotte (- United States (national) -)
Giovanatti, Neil (- United States (national) -)
Goldstein, Elena (Massachusetts)
Gradowski, Kathryn (- United States (national) -)
Grieco, Matthew William (- United States (national) -)
Halloran, Kathleen Ann (- United States (national) -)
Homer, Rachel F. (Massachusetts)
Hunger, Sarah A. (- United States (national) -)
Hyman, Nathaniel J. (- United States (national) -)
Jamieson, Keith (- United States (national) -)
Kassab, Vanessa L. (- United States (national) -)
Koch, Robert A. (- United States (national) -)
Kramer, Elizabeth C. (- United States (national) -)
Liston, Ian R. (- United States (national) -)
Lumelsky, Anna Esther (- United States (national) -)
Magenis, Sean D. (- United States (national) -)
Mendrala, Andrew C. (- United States (national) -)
Morejon, Amanda I. (- United States (national) -)
Moskowitz, David (- United States (national) -)
Muqaddam, Rabia (- United States (national) -)
Murdukhayeva, Ester (- United States (national) -)
Newman, Michael Louis (- United States (national) -)
Nugent, Victoria S. (Massachusetts)
Palmer, Jessica L. (- United States (national) -)
Rayner, Ewan Christopher (- United States (national) -)
Reyes, Natasha Adriana (- United States (national) -)
Richie, Joseph Robert (- United States (national) -)
Ring, Patrick (- United States (national) -)
Roberts, Katharine M. (- United States (national) -)
Rose, Jonathan T. (- United States (national) -)
Salmon, Leigh (- United States (national) -)
Schellenberg, Kali J. (Massachusetts)
Sepe, Cristina (- United States (national) -)
Shavit, Yael (- United States (national) -)
Simon, Andrew (- United States (national) -)
Skold, Michael Kenneth (- United States (national) -)
Srividya, Panchalam Seshan (- United States (national) -)
Stanley, James Edward (- United States (national) -)
Bruns, Michael Benjamin (Massachusetts)
Farquhar, Rayford A. (Massachusetts)
Freeman, Mark R. (- United States (national) -)
George, Abraham R. (- United States (national) -)
Lockhart, Donald Campbell (- United States (national) -)
McArthur, Eric Dean (- United States (national) -)
Myers, Steven A. (- United States (national) -)
Abelson, Dana A. (- United States (national) -)
Berman, Steve W. (- United States (national) -)
Engelen, Breanna Van (- United States (national) -)
Grant, John (- United States (national) -)
Melanson, Raffi (- United States (national) -)
Pershing, Abigail (- United States (national) -)
Stern, Heidi Parry (- United States (national) -)
See docket on RECAP: https://www.courtlistener.com/docket/69778837/somerville-public-schools-v-trump-font-colorred-bdo-not-docket-in/
Last updated Nov. 10, 2025, 11 p.m.
State / Territory:
Case Type(s):
Presidential/Gubernatorial Authority
Special Collection(s):
Trump Administration 2.0: Challenges to the Government
Key Dates
Filing Date: March 24, 2025
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
Somerville Public Schools, Easthampton Public Schools, American Federation of Teachers (AFT), AFT Massachusetts, American Federation of State, County and Municipal Employees (AFSCME) Council 93, American Association of University Professors (AAUP), and Service Employees International Union (SEIU). Public school districts and national and state-level labor unions representing educators, education workers, and academic professionals.
Plaintiff Type(s):
Non-profit NON-religious organization
Attorney Organizations:
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
United States of America (- United States (national) -), Federal
Department of Education (- 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 Massachusetts 1:25-cv-10677
U.S. Court of Appeals for the First Circuit 25-1495
Supreme Court of the United States 25-01203
U.S. Court of Appeals for the First Circuit 25-1500
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: None Yet / None
Relief Granted:
Preliminary injunction / Temp. restraining order
Source of Relief:
Content of Injunction:
Other requirements regarding hiring, promotion, retention
Reinstatement (job, contract, grant, etc.)
Issues
General/Misc.:
Public benefits (includes, e.g., in-state tuition, govt. jobs)