604 U.S. 650
SCOTUS2025Background
- The Department of Education abruptly decided to terminate over 100 previously awarded teacher training grants (TQP and SEED) in February 2025, citing a new internal directive on compliance with “merit, fairness, and excellence” and opposition to DEI (diversity, equity, and inclusion) programs.
- Eight states sued in the District of Massachusetts, alleging these mass grant terminations were arbitrary, capricious, and unlawful under the Administrative Procedure Act (APA).
- The District Court issued a temporary restraining order (TRO) on March 10, 2025, restoring the status quo and temporarily blocking the Department’s en-masse grant cancellations while considering a preliminary injunction.
- The Department sought to stay the TRO, but both the District Court and the First Circuit denied relief; the Department then applied to the Supreme Court for an emergency stay pending appeal.
- The Supreme Court’s majority treated the TRO as a preliminary injunction, found the government’s position likely correct on jurisdiction and irreparable harm, and granted the application to stay the District Court’s order pending appeal.
- The ruling generated strong dissents, emphasizing lack of urgency, grave harms from grant cancellation, and procedural concerns about emergency intervention at the TRO stage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Arbitrary, Capricious Agency Action (APA) | The abrupt, mass grant termination without individualized review or explanation violates APA requirements. | The terminations are within agency discretion, and the existence of noncompliance or inconsistency with new policy justifies the actions. | Not specifically resolved; Court focused on jurisdiction and remedial questions, not merits. |
| Jurisdiction – Proper Forum (District Court vs. Court of Federal Claims) | APA action properly belongs in district court, even if outcome affects disbursement of federal funds. | Only the Court of Federal Claims has jurisdiction for claims that effectively enforce a contractual obligation to pay money. | Court leans toward government position: relief sought resembles money damages, so district court jurisdiction questioned. |
| Appellate Review of TRO | TROs are non-appealable and should not be reviewed at this stage; normal process should proceed. | The TRO functions as a preliminary injunction, given duration and effect, and is therefore appealable. | Supreme Court construes the TRO as an appealable preliminary injunction and grants the stay. |
| Equities & Irreparable Harm | States and public institutions face immediate, unrecoverable harm if grants are terminated; government faces no concrete harm if TRO stands. | Once funds are disbursed, government likely can’t recover; irreparable harm justifies stay. | Court finds for government, grants stay; dissents argue equities were misweighed. |
Key Cases Cited
- Sampson v. Murray, 415 U.S. 61 (orders like the TRO at issue can be treated as preliminary injunctions if they have lasting effect)
- Bowen v. Massachusetts, 487 U.S. 879 (distinguishes between APA review and suits for money damages)
- Great-West Life & Annuity Ins. Co. v. Knudson, 534 U.S. 204 (explanation of when specific relief operates as money damages, thus affecting jurisdiction)
- Motor Vehicle Mfrs. Ass’n of the United States, Inc. v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29 (arbitrary and capricious standard under the APA)
- Hollingsworth v. Perry, 558 U.S. 183 (applicants for stays must show likelihood of irreparable harm)