Case: Washington State Association of Head Start and Early Childhood Education and Assistance Program v. Kennedy

2:25-cv-00781 | U.S. District Court for the Western District of Washington

Filed Date: April 28, 2025

Case Ongoing

Clearinghouse coding complete

Case Summary

This lawsuit challenges the Trump Administration’s efforts to dismantle—via mass layoffs and office closures—the Head Start program, a Congressionally-established federal program that provides young children of low-income families “a comprehensive program to meet their emotional, social, health, nutritional and psychological needs.” Since its launch in 1965, Head Start has “successfully improved the educational, health, social, and economic outcomes for families and children, particularly Black…

This lawsuit challenges the Trump Administration’s efforts to dismantle—via mass layoffs and office closures—the Head Start program, a Congressionally-established federal program that provides young children of low-income families “a comprehensive program to meet their emotional, social, health, nutritional and psychological needs.” Since its launch in 1965, Head Start has “successfully improved the educational, health, social, and economic outcomes for families and children, particularly Black children and other children of color, children with disabilities, children from dual-language and immigrant families, and children in rural communities, as Congress envisioned.”The Head Start Act, as amended by the Improving Head Start for School Readiness Act of 2007, requires the Secretary of HHS to undertake two main categories of action: (1) allocate funds to agencies that administer Head Start services, and (2) maintain sufficient staff to perform the guidance, oversight, monitoring, and grant administration functions mandated by Congress in the Head Start Act. 42 U.S.C. § 9835; 42 U.S.C. § 9836(d), (f); 42 U.S.C. § 9843(c).

On April 28, 2025, six state Head Start programs—Washington, Wisconsin, Illinois, Pennsylvania, Oregon, and California—filed this lawsuit in the United States District Court for the Western District of Washington against the Department of Health and Human Services (HHS) and its Secretary, Robert F. Kennedy Jr.; the Administration for Children and Families (ACF) and its Acting Assistant Secretary, Andrew Gradison; and the Office of Head Start (OHS) and its Acting Director, Tara Hooban. The case was assigned to District Judge Ricardo S. Martinez. 

The Plaintiffs challenged a series of actions by the Trump administration that seek to eliminate Head Start programs, alleging that the Defendants’ actions violated the Separation of Powers, the Spending Clause, the Due Process Clause, the First Amendment, the Administrative Procedure Act, and Section 504 of the Rehabilitation Act: First, on March 14, 2025, Defendants informed agencies that the OHS would not approve the use of federal funding “for any training and technical assistance (TTA) or other program expenditures that promote or take part in diversity, equity, and inclusion (DEI) initiatives.” Second, on April 1, 2025, HHS closed half of its regional offices and instituted mass layoffs. Third, on April 10, 2025, the Office of Management and Budget (OMB) issued a memorandum about the 2026 HHS discretionary budget, which directed HHS to work with OMB “to ensure to the extent allowable FY 2025 funds are made available to close out the program.” Fourth, on April 16, 2025, HHS imposed a new requirement for agencies to certify that “they do not, and will not during the term of this financial assistance award, operate any programs that advance or promote DEI, DEIA, or discriminatory equity ideology in violation of Federal anti-discrimination laws,” or face clawback of funds or liability under the False Claims Act.

On May 13, 2025, the Plaintiffs filed an amended complaint. The Amended Complaint introduced a new allegedly unlawful action by the Defendants: the systematic delay in designation renewal decisions for Head Start agencies, which has caused harm to approximately 80 programs. It also included updated facts, such as Secretary Kennedy acknowledging that about 20% of the OHS staff layoffs might have been “mistakes.” Finally, in the Amended Complaint, the Plaintiffs modified the requested relief to mandate that Defendants either reinstate terminated federal employees or hire staff sufficient to fulfill OHS responsibilities.

Three days later, on May 16, the Plaintiffs filed a motion for a PI seeking to enjoin the Trump Administration’s aforementioned efforts to eliminate the Head Start Program. Defendants filed a memorandum in opposition to the motion for a PI on June 6, 2025, arguing that their challenged actions are instead a “consolidation and streamlining of agency functions” aimed at “reduc[ing] redundancy and allow[ing] HHS to perform its core functions more efficiently,” “without impacting critical services.” They also argued that Plaintiffs’ harm is too speculative, as they only “hypothesize about harms that may befall them if their members do, or do not, comply with the DEI Letter or DEIA Certification or if HHS is unable to provide a particular service or function.”

In the pendency of the PI motion, on July 14, 2025, HHS issued a directive reinterpreting the phrase “federal public benefit” in the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) to include Head Start effective immediately, thereby excluding all “non-qualified” immigrants from Head Start programming, contrary to 27 years of agency practice. On July 15, the Plaintiffs filed a motion to amend their First Amended Complaint to add additional claims arising from the July 14 directive and moved for a Temporary Restraining Order solely based on and seeking emergency relief for the new claims and seeking to postpone the implementation date of the directive. Because the Defendants stipulated in another action to not implementing the directive with regard to Head Start programs until September 10, 2025 in all plaintiff states, the court found the requested relief in Plaintiffs’ TRO moot for the duration of a TRO Order, and converted the Motion into one for a PI on August 8. 

The motion to amend the complaint was granted, and on August 19, 2025, the Plaintiffs filed their Second Amended Complaint as described above. The Defendants filed a motion to dismiss the Second Amended Complaint, alleging that (1) the court lacks jurisdiction to Plaintiffs’ claims in the “pre-enforcement stage, where no actual harms have occurred over the six months since HHS has taken the challenged actions, and where Plaintiffs’ speculation about what may happen in the future does not constitute imminent or substantial injury”; (2) the court lacks jurisdiction to adjudicate challenges to HHS’s employment decisions under the Civil Service Reform Act; and (3) even if the court had jurisdiction, plaintiffs fail to state a claim.

After a hearing on the PI motion on August 5 and September 9, 2025, the court granted the PI on September 11. 2025 WL 2581890. The court found the Plaintiffs were likely to succeed on their claims that HHS’s July 14 Directive reinterpreting “federal public benefit” to exclude “non-qualified” immigrants violated the APA and Head Start Act by being “contrary to law, in excess of statutory authority, arbitrary and capricious, and is procedurally deficient.”

On October 1, 2025, Defendants filed a motion to stay the deadline to file a reply to the Motion to Dismiss Plaintiffs’ Second Amended Complaint in light of the federal government shutdown. The court granted the motion the next day.

After the government reopened, on November 6, 2025, Defendants filed a notice of appeal in the U.S. Court of Appeals for Ninth Circuit of the September 11, 2025, preliminary injunction.

The case is ongoing. 

Summary Authors

Scott Shuchart (5/7/2025)

Emma Vayda (7/9/2025)

Madena Mustafa (11/21/2025)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69962650/parties/washington-state-association-of-head-start-and-early-childhood-education/


Judge(s)
Attorney for Plaintiff

Attorney, Kevin M.

Baker, La Rond (Washington)

Calvo-Friedman, Jennesa (Washington)

Attorney for Defendant

Attorney, Kristin Berger

Attorney, Mr. Andrew

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Documents in the Clearinghouse

Document
1

2:25-cv-00781

Complaint for Declaratory and Injunctive Relief

April 28, 2025

April 28, 2025

Complaint
31

2:25-cv-00781

Amended Complaint for Declaratory and Injunctive Relief

May 13, 2025

May 13, 2025

Complaint
37

2:25-cv-00781

Plaintiffs' Motion for a Preliminary Injunction

Washington State Association of Head Start and Early Childhood Assistance and Education Program v. Kennedy Jr.

May 16, 2025

May 16, 2025

Pleading / Motion / Brief
79

2:25-cv-00781

Plaintiffs' Motion for Temporary Restraining Order/To Postpone Effective Date of Agency Action

Washington State Association of Head Start and Early Childhood Assistance and Education Program v. Kennedy

July 21, 2025

July 21, 2025

Pleading / Motion / Brief
79

2:25-cv-00781

Plaintiffs' Motion for Temporary Restraining Order/ To Postpone Effective Date of Agency Action

Washington State Association of Head Start and Early Childhood Assistance and Education Program v. Kennedy

July 21, 2025

July 21, 2025

Pleading / Motion / Brief
103

2:25-cv-00781

Second Amended Complaint for Declaratory and Injunctive Relief

Washington State Association of Head Start and Early Childhood Assistance and Education Program v. Kennedy

Aug. 19, 2025

Aug. 19, 2025

Complaint
116

2:25-cv-00781

Defendants’ Motion To Dismiss Plaintiffs’ Second Amended Complaint

Washington State Association of Head Start and Early Childhood Education and Assistance Program et al. v. Kennedy et al.

Sept. 5, 2025

Sept. 5, 2025

Pleading / Motion / Brief
120

2:25-cv-00781

Order Granting Motion for Preliminary Injunction

Washington State Association of Head Start and Early Childhood Education and Assistance Program et al. v. Kennedy et al.

Sept. 11, 2025

Sept. 11, 2025

Order/Opinion

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/69962650/washington-state-association-of-head-start-and-early-childhood-education/

Last updated Nov. 28, 2025, 2:58 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT for Declaratory and Injunctive Relief against All Defendants with JURY DEMAND (Receipt # AWAWDC-8950434) Attorney La Rond Baker added to party Washington State Association of Head Start and Early Childhood Education and Assistance Program(pty:pla), Attorney La Rond Baker added to party Wisconsin Head Start Association(pty:pla), Attorney La Rond Baker added to party Illinois Head Start Association(pty:pla), Attorney La Rond Baker added to party Family Forward Oregon(pty:pla), Attorney La Rond Baker added to party Parent Voices Oakland(pty:pla) filed by Parent Voices Oakland, Illinois Head Start Association, Wisconsin Head Start Association, Washington State Association of Head Start and Early Childhood Education and Assistance Program, Family Forward Oregon. (Attachments: # 1 Civil Cover Sheet)(Baker, La Rond) Modified on 4/30/2025 to edit jury demand info. (RE). (Entered: 04/28/2025)

1 Civil Cover Sheet

View on PACER

April 28, 2025

April 28, 2025

Clearinghouse
2

Notice of Filing Deficiency re 1 Complaint. ***Action Required*** Improper Signature - Secondary Attorney(s), Jury Demand Improperly Indicated.See attached letter for more information and instructions. (RE) (Entered: 04/30/2025)

April 30, 2025

April 30, 2025

3

NOTICE of Appearance by attorney Brent Low on behalf of Plaintiffs Washington State Association of Head Start and Early Childhood Education and Assistance Program, Wisconsin Head Start Association, Illinois Head Start Association, Pennsylvania Head Start Association, Family Forward Oregon, Parent Voices Oakland. (Low, Brent) (Entered: 04/30/2025)

April 30, 2025

April 30, 2025

4

PRAECIPE TO ISSUE SUMMONS, proposed for Robert F. Kennedy, Jr. and other defendants as attached hereto, by Plaintiffs Washington State Association of Head Start and Early Childhood Education and Assistance Program, Wisconsin Head Start Association, Illinois Head Start Association, Pennsylvania Head Start Association, Family Forward Oregon, Parent Voices Oakland (Attachments: # 1 Summons -Administration for Children and Families, # 2 Summons -Andrew Gradison, # 3 Summons -United States Department of Health and Human Services, # 4 Summons -Tara Hooban, # 5 Summons -Office of Head Start)(Baker, La Rond) (Entered: 04/30/2025)

April 30, 2025

April 30, 2025

Disclosure Statement - Notice of Deadlines

April 30, 2025

April 30, 2025

Add and Terminate Judges

April 30, 2025

April 30, 2025

Judge Ricardo S. Martinez added. (RE)

April 30, 2025

April 30, 2025

NOTICE: Pursuant to Fed.R.Civ.P 7.1(a)(1), Plaintiff(s) Washington State Association of Head Start and Early Childhood Education and Assistance Program, Wisconsin Head Start Association, Illinois Head Start Association, Pennsylvania Head Start Association, Family Forward Oregon, and Parent Voices Oakland must file a Corporate Disclosure Statement by 5/7/2025. If applicable, a Diversity Disclosure Statement may be required pursuant to Fed.R.Civ.P 7.1(a)(2). In order to properly notify the Court, use the event Corporate/Diversity Disclosure Statement located in CM/ECF under Other Filings, Other Documents. (RE)

April 30, 2025

April 30, 2025

5

APPLICATION OF ATTORNEY Sania Chandrani FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8956786 (Baker, La Rond) (Entered: 05/01/2025)

May 1, 2025

May 1, 2025

6

APPLICATION OF ATTORNEY Fawn Rajbhandari-Korr FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8956788 (Baker, La Rond) (Entered: 05/01/2025)

May 1, 2025

May 1, 2025

7

APPLICATION OF ATTORNEY Jennesa Calvo-Friedman FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8956789 (Baker, La Rond) (Entered: 05/01/2025)

May 1, 2025

May 1, 2025

8

APPLICATION OF ATTORNEY Kevin M. Fee FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8956791 (Baker, La Rond) (Entered: 05/01/2025)

May 1, 2025

May 1, 2025

9

APPLICATION OF ATTORNEY Laboni A. Hoq FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8956792 (Baker, La Rond) (Entered: 05/01/2025)

May 1, 2025

May 1, 2025

10

APPLICATION OF ATTORNEY Lindsay Nako FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8956793 (Baker, La Rond) (Entered: 05/01/2025)

May 1, 2025

May 1, 2025

11

APPLICATION OF ATTORNEY Linda S. Morris FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8956794 (Baker, La Rond) (Entered: 05/01/2025)

May 1, 2025

May 1, 2025

12

APPLICATION OF ATTORNEY Lori Rifkin FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8956796 (Baker, La Rond) (Entered: 05/01/2025)

May 1, 2025

May 1, 2025

13

APPLICATION OF ATTORNEY Ming-Qi Chu FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8956797 (Baker, La Rond) (Entered: 05/01/2025)

May 1, 2025

May 1, 2025

14

APPLICATION OF ATTORNEY Megan Flynn FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8956798 (Baker, La Rond) (Entered: 05/01/2025)

May 1, 2025

May 1, 2025

15

APPLICATION OF ATTORNEY Meredith Dixon FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8956799 (Baker, La Rond) (Entered: 05/01/2025)

May 1, 2025

May 1, 2025

16

APPLICATION OF ATTORNEY Michelle Fraling FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8956800 (Baker, La Rond) (Entered: 05/01/2025)

May 1, 2025

May 1, 2025

17

APPLICATION OF ATTORNEY Allison Siebeneck FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8956801 (Baker, La Rond) (Entered: 05/01/2025)

May 1, 2025

May 1, 2025

18

ORDER re 11 Application for Leave to Appear Pro Hac Vice, 14 Application for Leave to Appear Pro Hac Vice, 15 Application for Leave to Appear Pro Hac Vice, 6 Application for Leave to Appear Pro Hac Vice, 8 Application for Leave to Appear Pro Hac Vice, 17 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorneys Fawn Rajbhandari-Korr,Kevin M. Fee, Jr,Linda Morris,Megan Flynn,Meredith Dixon,Allison N. Siebeneck for Plaintiffs Family Forward Oregon, for Illinois Head Start Association, for Parent Voices Oakland, for Pennsylvania Head Start Association, for Washington State Association of Head Start and Early Childhood Education and Assistance Program, and for Wisconsin Head Start Association, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(AVC) (Entered: 05/02/2025)

May 2, 2025

May 2, 2025

19

Summons(es) Electronically Issued as to defendant(s) Administration for Children and Families, Andrew Gradison, Tara Hooban, Illinois Head Start Association, Robert F Kennedy, Jr, Office of Head Start. (Attachments: # 1 Summons, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons)(TE) (Entered: 05/02/2025)

May 2, 2025

May 2, 2025

Notice to PHV and Local Counsel Unable to Process Application

May 2, 2025

May 2, 2025

Order on Application for Leave to Appear Pro Hac Vice

May 2, 2025

May 2, 2025

Application for Leave to Appear Pro Hac Vice 12, Application for Leave to Appear Pro Hac Vice 7, Application for Leave to Appear Pro Hac Vice 13, Application for Leave to Appear Pro Hac Vice 9, Application for Leave to Appear Pro Hac Vice 16, Application for Leave to Appear Pro Hac Vice 5, Application for Leave to Appear Pro Hac Vice 10 by attorney Sania Chandrani, Jennesa Calvo-Friedman, Laboni Hoq, Lindsey Nako, Lori Rifkin, Ming-Chi Chu, and Michelle Fraling will not be processed at this time. The Pro Hac attorney must submit a Pro Hac Vice access request via Manage My Account on PACER, under the Maintenance tab. See page 2 of the Pro Hac Vice Application Guide for detailed instructions. Please contact the Attorney Admissions Clerk at 206-370-8400 or WAWD_Admissions@wawd.uscourts.gov with additional questions. (Ad hoc Attorney Sania Chandrani, Jennesa Calvo-Friedman, Laboni Hoq, Lindsey Nako, Lori Rifkin, Ming-Chi Chu, and Michelle Fraling) (AVC)

May 2, 2025

May 2, 2025

20

NOTICE of Appearance by attorney David V Montes on behalf of Plaintiffs Family Forward Oregon, Illinois Head Start Association, Parent Voices Oakland, Pennsylvania Head Start Association, Washington State Association of Head Start and Early Childhood Education and Assistance Program, Wisconsin Head Start Association. (Montes, David) (Entered: 05/05/2025)

May 5, 2025

May 5, 2025

RECAP
21

DEMAND for JURY TRIAL by All Plaintiffs (Baker, La Rond) (Entered: 05/05/2025)

May 5, 2025

May 5, 2025

22

NOTICE of Appearance by attorney David V Montes on behalf of Plaintiffs Family Forward Oregon, Illinois Head Start Association, Parent Voices Oakland, Pennsylvania Head Start Association, Washington State Association of Head Start and Early Childhood Education and Assistance Program, Wisconsin Head Start Association. (Montes, David) (Entered: 05/05/2025)

May 5, 2025

May 5, 2025

23

CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1(a)(1). Filed by Washington State Association of Head Start and Early Childhood Education and Assistance Program. (Baker, La Rond) (Entered: 05/07/2025)

May 7, 2025

May 7, 2025

24

CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1(a)(1). Filed by Family Forward Oregon. (Baker, La Rond) (Entered: 05/07/2025)

May 7, 2025

May 7, 2025

25

CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1(a)(1). Filed by Illinois Head Start Association. (Baker, La Rond) (Entered: 05/07/2025)

May 7, 2025

May 7, 2025

26

CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1(a)(1). Filed by Pennsylvania Head Start Association. (Baker, La Rond) (Entered: 05/07/2025)

May 7, 2025

May 7, 2025

27

CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1(a)(1). Filed by Parent Voices Oakland. (Baker, La Rond) (Entered: 05/07/2025)

May 7, 2025

May 7, 2025

28

CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1(a)(1). Filed by Wisconsin Head Start Association. (Baker, La Rond) (Entered: 05/07/2025)

May 7, 2025

May 7, 2025

29

ORDER re 7 Application for Leave to Appear Pro Hac Vice, 9 Application for Leave to Appear Pro Hac Vice, 16 Application for Leave to Appear Pro Hac Vice, 5 Application for Leave to Appear Pro Hac Vice, 10 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorneys Sania Chandrani,Jennesa Calvo-Friedman,Laboni Hoq,Lindsay Nako,Michelle Fraling for Plaintiffs Washington State Association of Head Start and Early Childhood Education and Assistance Program, Wisconsin Head Start Association, Illinois Head Start Association, Pennsylvania Head Start Association, Family Forward Oregon, Parent Voices Oakland, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(HH) (Entered: 05/08/2025)

May 8, 2025

May 8, 2025

30

ORDER re 12 Application for Leave to Appear Pro Hac Vice, 13 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorneys Lori Rifkin,Ming-Qi Chu for Plaintiffs Washington State Association of Head Start and Early Childhood Education and Assistance Program, Wisconsin Head Start Association, Illinoise Head Start Association, Pennsylvania Head Start Association, Family Foward Oregon, and Parent Voices Oakland, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(HH) (Entered: 05/08/2025)

May 8, 2025

May 8, 2025

Order on Application for Leave to Appear Pro Hac Vice

May 8, 2025

May 8, 2025

31

AMENDED COMPLAINT against defendant(s) Administration for Children and Families, Andrew Gradison, Robert F Kennedy, Jr, Office of Head Start, United States Department of Health and Human Services, Tala Hooban with JURY DEMAND filed by Parent Voices Oakland, Illinois Head Start Association, Wisconsin Head Start Association, Pennsylvania Head Start Association, Washington State Association of Head Start and Early Childhood Education and Assistance Program, Family Forward Oregon.(Baker, La Rond) (Entered: 05/13/2025)

May 13, 2025

May 13, 2025

Clearinghouse
32

PRAECIPE TO ISSUE SUMMONS upon Tala Hooban by All Plaintiffs (Baker, La Rond) (Entered: 05/13/2025)

May 13, 2025

May 13, 2025

33

ORDER REGARDING INITIAL DISCLOSURES, JOINT STATUS REPORT AND EARLY SETTLEMENT by Judge Ricardo S. Martinez. FRCP 26(f) Conference Deadline is 6/10/2025, Initial Disclosure Deadline is 6/17/2025, Joint Status Report due by 6/24/2025. (LC) (Entered: 05/13/2025)

May 13, 2025

May 13, 2025

RECAP
34

AFFIDAVIT of Mailing of Summons and Complaint to Administration for Children and Families, Andrew Gradison, Office of Head Start, US Dep't of Health and Human Services, and Robert F. Kennedy, Jr. on 5/14/2025, filed by All Plaintiffs. (Attachments: # 1 Certificate of Service upon Andrew Gradison, # 2 Certificate of Service upon Office of Head Start, # 3 Certificate of Service upon US Dep't of Health and Human Services, # 4 Certificate of Service upon Robert F. Kennedy, Jr.)(Baker, La Rond) (Entered: 05/14/2025)

May 14, 2025

May 14, 2025

35

MOTION for Leave to File Declarations in Pseudonym, filed by All Plaintiffs. (Attachments: # 1 Proposed Order) Noting Date 6/13/2025, (Baker, La Rond) (Entered: 05/16/2025)

1 Proposed Order

View on RECAP

May 16, 2025

May 16, 2025

RECAP
36

DECLARATION of David Montes filed by All Plaintiffs re 35 MOTION for Leave to File Declarations in Pseudonym (Attachments: # 1 Exhibit A: Jane Doe Decl., # 2 Exhibit B: FFO Member A Decl., # 3 Exhibit C: FFO Member B Decl.)(Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

37

MOTION for Preliminary Injunction, filed by All Plaintiffs. Oral Argument Requested. (Attachments: # 1 Proposed Order) Noting Date 6/13/2025, (Baker, La Rond) (Entered: 05/16/2025)

1 Proposed Order

View on PACER

May 16, 2025

May 16, 2025

Clearinghouse
38

DECLARATION of Jennesa Calvo-Friedman filed by All Plaintiffs re 37 MOTION for Preliminary Injunction (Attachments: # 1 Exhibit 1: Head Start, # 2 Exhibit 2: Payment Request, # 3 Exhibit 3: elof-ohs-framework (2015), # 4 Exhibit 4: fy-2025, # 5 Exhibit 5: Mar. 14 DEI ltr., # 6 Exhibit 6: HS Grantees, # 7 Exhibit 7: hhs grants policy, # 8 Exhibit 8: HHS announces, # 9 Exhibit 9: Fact Sheet, # 10 Exhibit 10: Consolidating HS, # 11 Exhibit 11: RFK Jr says, # 12 Exhibit 12: OMB, # 13 Exhibit 13: Trump Budget, # 14 Exhibit 14: Can HS Survive, # 15 Exhibit 15: 1991 Multicultural, # 16 Exhibit 16: Letter to Alaska, # 17 Exhibit 17: Federal cuts, # 18 Exhibit 18: Alaska HS, # 19 Exhibit 19: How Trump's Funding, # 20 Exhibit 20: HHS DRI, # 21 Exhibit 21: AFGE v. Trump, # 22 Exhibit 22: Cal. lawmaker, # 23 Exhibit 23: I know the power, # 24 Exhibit 24: Funding cuts, # 25 Exhibit 25: HHS DRI PI, # 26 Exhibit 26: Held up, # 27 Exhibit 27: HHS makes big cuts, # 28 Exhibit 28: Trump cuts, # 29 Exhibit 29: Some Michigan, # 30 Exhibit 30: More than 12000, # 31 Exhibit 31: NJ HS, # 32 Exhibit 32: HHS DRI PI, # 33 Exhibit 33: Warren Cnty, # 34 Exhibit 34: Head Start, # 35 Exhibit 35: Nevadas, # 36 Exhibit 36: HS regional, # 37 Exhibit 37: HS director, # 38 Exhibit 38: Confusion, # 39 Exhibit 39: Ex HS)(Baker, La Rond) (Entered: 05/16/2025)

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May 16, 2025

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DECLARATION of JENNIE (MAUER) MAUNNAMALAI filed by All Plaintiffs re 37 MOTION for Preliminary Injunction (Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

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DECLARATION of Kara McFalls filed by All Plaintiffs re 37 MOTION for Preliminary Injunction (Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

41

DECLARATION of Lauri Morrison-Frichtlin filed by All Plaintiffs re 37 MOTION for Preliminary Injunction (Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

42

DECLARATION of Joel Ryan filed by All Plaintiffs re 37 MOTION for Preliminary Injunction (Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

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DECLARATION of Clarissa Doutherd filed by All Plaintiffs re 37 MOTION for Preliminary Injunction (Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

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DECLARATION of FFO Member A filed by All Plaintiffs re 37 MOTION for Preliminary Injunction (Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

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DECLARATION of FFO Member B filed by All Plaintiffs re 37 MOTION for Preliminary Injunction (Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

46

DECLARATION of Desiree Guerra filed by All Plaintiffs re 37 MOTION for Preliminary Injunction (Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

47

DECLARATION of Candice Vickers filed by All Plaintiffs re 37 MOTION for Preliminary Injunction (Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

48

DECLARATION of OSBORNIQUE WILLIAMS filed by All Plaintiffs re 37 MOTION for Preliminary Injunction (Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

49

DECLARATION of Khari Garvin filed by All Plaintiffs re 37 MOTION for Preliminary Injunction (Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

50

DECLARATION of Katherine Neas filed by All Plaintiffs re 37 MOTION for Preliminary Injunction (Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

51

DECLARATION of Martha Zaslow, PH.D filed by All Plaintiffs re 37 MOTION for Preliminary Injunction (Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

52

DECLARATION of Jane Doe filed by All Plaintiffs re 37 MOTION for Preliminary Injunction (Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

53

CERTIFICATE OF SERVICE by All Plaintiffs re 44 Declaration, 40 Declaration, 46 Declaration, 51 Declaration, 49 Declaration, 35 MOTION for Leave to File Declarations in Pseudonym, 47 Declaration, 52 Declaration, 37 MOTION for Preliminary Injunction, 38 Declaration,,,,, 42 Declaration, 43 Declaration, 50 Declaration, 39 Declaration, 45 Declaration, 41 Declaration, 48 Declaration, 36 Declaration, (Baker, La Rond) (Entered: 05/16/2025)

May 16, 2025

May 16, 2025

54

APPLICATION OF ATTORNEY Edward T. Waters FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-8988202 (Baker, La Rond) (Entered: 05/20/2025)

May 20, 2025

May 20, 2025

55

ORDER re 54 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Edward Todd Waters for All Plaintiffs by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(CDA) (Entered: 05/21/2025)

May 21, 2025

May 21, 2025

Order on Application for Leave to Appear Pro Hac Vice

May 21, 2025

May 21, 2025

56

NOTICE of Appearance by attorney Kristin Berger Johnson on behalf of Defendants Administration for Children and Families, Andrew Gradison, Tala Hooban, Tara Hooban, Robert F Kennedy, Jr, Office of Head Start, United States Department of Health and Human Services. (Johnson, Kristin) (Entered: 06/02/2025)

June 2, 2025

June 2, 2025

57

MOTION for Leave to File Over-Length Brief, filed by All Defendants. (Attachments: # 1 Proposed Order) Noting Date 6/2/2025, (Johnson, Kristin) (Entered: 06/02/2025)

June 2, 2025

June 2, 2025

58

ORDER granting in part and denying in part 57 Motion for Leave to File Over-Length Brief. The Court will permit Defendants' responsive briefing to Plaintiffs' preliminary injunction Motion to be up to 10,000 words. Plaintiffs' reply briefing is allotted up to 5,000 words. Signed by Judge Ricardo S. Martinez. (TE) (Entered: 06/04/2025)

June 4, 2025

June 4, 2025

59

RESPONSE, by All Defendants, to 37 MOTION for Preliminary Injunction . (Johnson, Kristin) (Entered: 06/06/2025)

June 6, 2025

June 6, 2025

RECAP
60

DECLARATION of Kristin B. Johnson filed by All Defendants re 37 MOTION for Preliminary Injunction (Attachments: # 1 Exhibit A)(Johnson, Kristin) (Entered: 06/06/2025)

June 6, 2025

June 6, 2025

61

APPLICATION OF ATTORNEY S. Starling Marshall FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-9018280 (Baker, La Rond) (Entered: 06/09/2025)

June 9, 2025

June 9, 2025

62

APPLICATION OF ATTORNEY Skye Mathieson FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-9018291 (Baker, La Rond) (Entered: 06/09/2025)

June 9, 2025

June 9, 2025

63

APPLICATION OF ATTORNEY Emily P. Golchini FOR LEAVE TO APPEAR PRO HAC VICE for All Plaintiffs (Fee Paid) Receipt No. AWAWDC-9018293 (Baker, La Rond) (Entered: 06/09/2025)

June 9, 2025

June 9, 2025

64

ORDER re 61 Application for Leave to Appear Pro Hac Vice, 62 Application for Leave to Appear Pro Hac Vice, 63 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorneys Emily Golchini, S Starling Marshall, and Skye Mathieson for Plaintiffs Family Forward Oregon, Illinois Head Start Association, Parent Voices Oakland, Pennsylvania Head Start Association, Washington State Association of Head Start and Early Childhood Education and Assistance Program, and Wisconsin Head Start Association, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(KB) (Entered: 06/09/2025)

June 9, 2025

June 9, 2025

Order on Application for Leave to Appear Pro Hac Vice

June 9, 2025

June 9, 2025

Set/Reset Deadlines

June 9, 2025

June 9, 2025

MINUTE ORDER (text only): Pursuant to the joint request of counsel and for good cause shown, the deadlines set forth in the Court's ORDER REGARDING INITIAL DISCLOSURES, JOINT STATUS REPORT AND EARLY SETTLEMENT, Dkt 33, are continued as follows: FRCP 26(f) Conference Deadline is 6/17/2025, Initial Disclosure Deadline is 6/24/2025, Joint Status Report due by 7/1/2025.(LC)

June 9, 2025

June 9, 2025

65

REPLY, filed by All Plaintiffs, TO RESPONSE to 37 MOTION for Preliminary Injunction (Baker, La Rond) (Entered: 06/13/2025)

June 13, 2025

June 13, 2025

66

ORDER granting Plaintiff's 35 MOTION for Leave to File Declarations in Pseudonym. Signed by Judge Ricardo S. Martinez. (APH) (Entered: 06/16/2025)

June 16, 2025

June 16, 2025

RECAP
67

Summons(es) Electronically Issued as to defendant(s) Tala Hooban. (APH) (Entered: 06/26/2025)

June 26, 2025

June 26, 2025

68

DECLARATION of Service re 31 Amended Complaint,, by All Plaintiffs (Baker, La Rond) (Entered: 06/26/2025)

June 26, 2025

June 26, 2025

69

JOINT STATUS REPORT signed by all parties. (Baker, La Rond) (Entered: 06/26/2025)

June 26, 2025

June 26, 2025

RECAP
70

NOTICE of Supplemental Authority by All Plaintiffs (Attachments: # 1 New York v. Kennedy Memorandum and Order)(Calvo-Friedman, Jennesa) (Entered: 07/03/2025)

1 New York v. Kennedy Memorandum and Order

View on RECAP

July 3, 2025

July 3, 2025

RECAP
71

AFFIDAVIT of Mailing of Summons and Complaint to The U.S. Department of Health and Human Services on 7/7/2025, filed by All Plaintiffs. (Baker, La Rond) (Entered: 07/08/2025)

July 8, 2025

July 8, 2025

72

AFFIDAVIT of Mailing of Summons and Complaint to Robert F. Kennedy, Jr. on 7/7/2025, filed by All Plaintiffs. (Baker, La Rond) (Entered: 07/08/2025)

July 8, 2025

July 8, 2025

73

AFFIDAVIT of Mailing of Summons and Complaint to Office of Head Start on 7/7/2025, filed by All Plaintiffs. (Baker, La Rond) (Entered: 07/08/2025)

July 8, 2025

July 8, 2025

74

AFFIDAVIT of Mailing of Summons and Complaint to Andrew Gradison on 7/7/2025, filed by All Plaintiffs. (Baker, La Rond) (Entered: 07/08/2025)

July 8, 2025

July 8, 2025

75

AFFIDAVIT of Mailing of Summons and Complaint to Administration for Children and Families on 7/7/2025, filed by All Plaintiffs. (Baker, La Rond) (Entered: 07/08/2025)

July 8, 2025

July 8, 2025

76

AFFIDAVIT of Mailing of Summons and Complaint to U.S. Attorney for the Western District of Washington on 7/7/2025, filed by All Plaintiffs. (Baker, La Rond) (Entered: 07/08/2025)

July 8, 2025

July 8, 2025

77

AFFIDAVIT of Mailing of Summons and Complaint to Attorney General of the United States on 7/7/2025, filed by All Plaintiffs. (Baker, La Rond) (Entered: 07/08/2025)

July 8, 2025

July 8, 2025

78

MOTION to Amend, filed by All Plaintiffs. (Attachments: # 1 Proposed Order Granting Motion for Leave to File Second Amended Complaint) Noting Date 8/5/2025, (Baker, La Rond Rifkin, Lori) Modified on 7/17/2025 (CJS). (Entered: 07/15/2025)

1 Proposed Order Granting Motion for Leave to File Second Amended Complaint

View on PACER

July 15, 2025

July 15, 2025

RECAP
79

MOTION for Temporary Restraining Order / to Postpone Effective Date of Agency Action, filed by All Plaintiffs. Oral Argument Requested. (Attachments: # 1 Proposed Order) Noting Date 7/21/2025, (Baker, La Rond) (Entered: 07/21/2025)

1 Proposed Order

View on RECAP

July 21, 2025

July 21, 2025

Clearinghouse
80

DECLARATION of Clarissa Doutherd filed by All Plaintiffs re 79 MOTION for Temporary Restraining Order / to Postpone Effective Date of Agency Action (Baker, La Rond) (Entered: 07/21/2025)

July 21, 2025

July 21, 2025

81

DECLARATION of Jennie (Mauer) Maunnamalai filed by All Plaintiffs re 79 MOTION for Temporary Restraining Order / to Postpone Effective Date of Agency Action (Baker, La Rond) (Entered: 07/21/2025)

July 21, 2025

July 21, 2025

RECAP
82

DECLARATION of Kara McFalls filed by All Plaintiffs re 79 MOTION for Temporary Restraining Order / to Postpone Effective Date of Agency Action (Baker, La Rond) (Entered: 07/21/2025)

July 21, 2025

July 21, 2025

83

DECLARATION of Lauri Morrison-Frichtl filed by All Plaintiffs re 79 MOTION for Temporary Restraining Order / to Postpone Effective Date of Agency Action (Baker, La Rond) (Entered: 07/21/2025)

July 21, 2025

July 21, 2025

RECAP
84

DECLARATION of Joel Ryan filed by All Plaintiffs re 79 MOTION for Temporary Restraining Order / to Postpone Effective Date of Agency Action (Baker, La Rond) (Entered: 07/21/2025)

July 21, 2025

July 21, 2025

RECAP
85

DECLARATION of Candice Williams filed by All Plaintiffs re 79 MOTION for Temporary Restraining Order / to Postpone Effective Date of Agency Action (Baker, La Rond) (Entered: 07/21/2025)

July 21, 2025

July 21, 2025

RECAP
86

NOTICE of Intent to Oppose re 79 MOTION for Temporary Restraining Order / to Postpone Effective Date of Agency Action ; filed by Defendants Administration for Children and Families, Andrew Gradison, Tala Hooban, Robert F Kennedy, Jr, Office of Head Start, United States Department of Health and Human Services. (Johnson, Kristin) (Entered: 07/22/2025)

July 22, 2025

July 22, 2025

87

RESPONSE, by Defendants Administration for Children and Families, Andrew Gradison, Tala Hooban, Robert F Kennedy, Jr, Office of Head Start, United States Department of Health and Human Services, to 79 MOTION for Temporary Restraining Order / to Postpone Effective Date of Agency Action. (Johnson, Kristin) (Entered: 07/23/2025)

July 23, 2025

July 23, 2025

88

DECLARATION of Kristin B. Johnson filed by Defendants Administration for Children and Families, Andrew Gradison, Tala Hooban, Robert F Kennedy, Jr, Office of Head Start, United States Department of Health and Human Services re 79 MOTION for Temporary Restraining Order / to Postpone Effective Date of Agency Action (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Johnson, Kristin) (Entered: 07/23/2025)

1 Exhibit A

View on RECAP

2 Exhibit B

View on RECAP

3 Exhibit C

View on RECAP

4 Exhibit D

View on RECAP

5 Exhibit E

View on RECAP

July 23, 2025

July 23, 2025

Case Details

State / Territory:

Washington

Case Type(s):

Education

Presidential/Gubernatorial Authority

Special Collection(s):

Trump Administration 2.0: Challenges to the Government

Key Dates

Filing Date: April 28, 2025

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

Several state Head Start advocacy organizations and programs

Attorney Organizations:

ACLU Affiliates (any)

ACLU National (all projects)

Impact Fund

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Department of Health and Human Services (- United States (national) -), Federal

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

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

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

Constitutional Clause(s):

Due Process

Freedom of speech/association

Separation of Powers

Spending/Appropriations Clauses

Other Dockets:

Western District of Washington 2:25-cv-00781

U.S. Court of Appeals for the Ninth Circuit 25-07072

Available Documents:

Any published opinion

Complaint (any)

Injunctive (or Injunctive-like) Relief

Trial Court Docket

Outcome

Prevailing Party: None Yet / None

Relief Sought:

Injunction

Relief Granted:

Injunction / Injunctive-like Settlement

Source of Relief:

Litigation

Issues

General/Misc.:

Education

Disability and Disability Rights:

Disability, unspecified

Presidential/Gubernatorial Authority:

Impoundment (mandatory spending)