Filed Date: April 24, 2025
Case Ongoing
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In this case, two organizations involved in research about education policies, practices, and methods sued the Department of Education and its Secretary. The plaintiffs challenged actions taken by the Department regarding the Institute for Education Sciences (IES) and its centers. Under the Education Sciences Reform Act (ESRA), the Department, through IES, is charged with conducting, assessing, collecting, and disseminating research about education practices and policies in the U.S. "Through IES and its Centers, Congress sought to improve both the quantity and quality of educational data collection."
On March 20, 2025, President Trump signed Executive Order 14,242, titled "Improving Education Outcomes by Empowering Parents, States, and Communities." In this order, President Trump instructed the Secretary "to the maximum extent appropriate and permitted by law, [to] take all necessary steps to facilitate the closure of the Department of Education." In keeping with this directive, the Department canceled most of IES's contracts with independent contractors that it used to collect, analyze, and publish educational data. On March 11, the Department also announced a Reduction in Force of nearly 50% of its workforce.
On April 24, 2025, the plaintiffs filed suit in the District Court for the District of Columbia. The plaintiffs alleged that the Department's actions "will limit the availability and access of significant datasets that are needed to identify, investigate, evaluate, and improve educational outcomes." Furthermore, the plaintiffs alleged that the Department's actions would prevent the IES from carrying out its instructions from Congress to collect and disseminate educational data. Therefore, the plaintiffs argued that the defendant's actions exceeded statutory authority, were not in accordance with law, and were arbitrary and capricious under the Administrative Procedure Act (APA). The plaintiffs also claimed the actions violated the Constitution's separation of powers principles and exceeded the agency's statutory authority under ERSA. The plaintiffs asked the court to declare that the defendants had violated the APA, to enjoin the defendants from refusing to fulfill contracts or destroying any datasets in existence, and to order the defendants to reinstate cancelled contracts and a sufficient workforce to carry out the IES's duties.
The case was assigned to District Judge Trevor N. McFadden. On May 2, the plaintiffs filed a motion for a preliminary injunction, telling the court that any delay in granting relief would cause them irreparable harm, given the President's directives to the Department. On May 5, the defendants moved for a stay. The defendants pointed to another related case that was also assigned to Judge McFadden, Association for Education Finance and Policy v. McMahon, arguing that since the plaintiffs in both cases had moved for preliminary injunctions seeking identical relief, the court here should stay the proceedings until a decision was reached in the other case on the preliminary injunction. On May 6, Judge McFadden denied the defendants' motion for a stay. Judge McFadden said that the defendants had only argued that they would suffer hardship from having to litigate two similar cases at the same time, which does not warrant a stay. Furthermore, the judge said that comity concerns do not exist in this case, since both matters were before the same court, rather than before courts in different jurisdictions.
On May 19, the judge held a hearing on the plaintiffs' motion for a preliminary injunction. The court denied the plaintiffs' motion on June 3, finding that the plaintiffs were "seeking wholesale correction of general agency operations and bundling together claims to pursue outsized relief." Rather than bringing a claim against a discrete agency action as required by the APA, the plaintiffs were challenging a programmatic decision, the reduction of workforce and services by the Department. Therefore, the court found that the plaintiffs were not bringing a justiciable claim under the APA, dooming their request for a preliminary injunction based on the APA.
Turning to the plaintiffs' constitutional claims, the court also found them deficient, stating that "if every statutory compliance issue triggered separation of powers concerns, virtually all APA cases would balloon into disputes of constitutional proportions." Instead, the plaintiffs' constitutional claims in this case were simply statutory violation claims in disguise. Therefore, the court found that the plaintiffs failed to state a plausible claim for relief under the Constitution. Given these deficiencies, the court said the plaintiffs were unlikely to prevail on the merits of their claims and denied their request for a preliminary injunction. 2025 WL 1568301.
On June 26, the parties informed the court of a proposed schedule for the case: The plaintiffs were to file an amended complaint by July 21, and the defendants were to file a motion to dismiss on or before September 18.
The case is ongoing.
Summary Authors
Jeremiah Price (6/3/2025)
Association for Education Finance and Policy v. McMahon, District of District of Columbia (2025)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69936678/parties/national-academy-of-education-v-department-of-education/
McFadden, Trevor Neil (District of Columbia)
Burke, Colin (District of Columbia)
Fajana, Morenike (District of Columbia)
Grisafi, Lily (District of Columbia)
Georgiev-Remmel, Dimitar (District of Columbia)
See docket on RECAP: https://www.courtlistener.com/docket/69936678/national-academy-of-education-v-department-of-education/
Last updated July 7, 2025, 12:45 p.m.