Crawford v. Walsh, Civil Action No. 2021-2238

Plaintiff Angela Crawford, a Georgia resident who lost her job due to COVID-19, received Pandemic Unemployment Assistance (PUA) under the CARES Act until Georgia ended its agreement with the Secretary of Labor effective June 26, 2021.
Termination of Georgia’s agreement ended Crawford’s sole source of income; she sought a TRO and preliminary injunction requiring the Secretary to continue PUA payments.
Defendant Martin J. Walsh, Secretary of Labor, moved to dismiss under Fed. R. Civ. P. 12(b)(6) and opposed injunctive relief.
Crawford argued the CARES Act’s language is mandatory and the Secretary has a ministerial duty to continue payments to covered individuals regardless of a State’s decision to withdraw.
The Secretary pointed to 15 U.S.C. § 9021(f)(1) and implementing regulations (adopting Disaster Unemployment Assistance rules) showing benefits are provided only through agreements with States and only while an agreement is in effect.
The Court dismissed the complaint for failure to state a claim and denied the TRO/preliminary injunction because the statute and regulations limit PUA to periods when a State agreement is in effect; the Secretary had no duty to pay after Georgia ended its agreement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Secretary is legally required to continue PUA payments to individuals after a State ends its agreement	CAREW Act mandates the Secretary “shall provide” benefits to covered individuals; duty is ministerial and independent of state participation	CARES Act conditions benefits on agreements with States; Secretary need not pay once a State ends its agreement	Court: Secretary not obligated to continue payments after State terminates agreement; complaint fails to state a claim
Whether a TRO / preliminary injunction should issue to compel continued PUA payments	Irreparable harm from loss of sole income justifies emergency relief; statutory command requires relief	Extraordinary relief not warranted where statute/regulations foreclose the claimed right; plaintiff unlikely to succeed on merits	Court: Denied TRO and preliminary injunction; plaintiff failed to show likelihood of success on the merits

Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (pleading standard requires plausible factual allegations).
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (complaint must raise claim above speculative level).
Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (U.S. 2008) (standard for preliminary injunction requires likelihood of success and irreparable harm).
Haines v. Kerner, 404 U.S. 519 (U.S. 1972) (pro se pleadings held to less stringent standards).
Sherley v. Sebelius, 644 F.3d 388 (D.C. Cir. 2011) (characterizing preliminary injunction as extraordinary relief).
J.D. v. Azar, 925 F.3d 1291 (D.C. Cir. 2019) (four-factor framework for injunctive relief).
Browning v. Clinton, 292 F.3d 235 (D.C. Cir. 2002) (Rule 12(b)(6) tests legal sufficiency of complaint).