National Treasury Employees Union v. Russell T. Vought
25-5091
D.C. Cir.Apr 28, 2025Background
- The Consumer Financial Protection Bureau (CFPB) sought to reduce its workforce via a reduction in force (RIF) in accordance with directives from President Trump.
- A district court entered a preliminary injunction, prohibiting the CFPB from implementing any RIFs, effectively maintaining prior staffing levels.
- The government appealed and was granted a stay in substantial part, allowing for some RIFs consistent with the CFPB’s statutory duties.
- After the stay, the CFPB issued RIF notices to over 80% of its workforce; plaintiffs sought renewed judicial intervention, claiming statutory services could not be maintained.
- The district court issued an order halting the RIF again without a finding of specific, actual harm to plaintiffs.
- The dissenting judge argues the district court’s actions in modifying the injunction violate separation of powers and improperly involve the judiciary in executive agency management.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| District court power to halt CFPB’s RIF | RIF prevents the agency from fulfilling statutory duties; needs court protection | CFPB leadership must have discretion to manage workforce; no specific harm shown | District court halted RIF but dissent argues this overstepped, violating separation of powers |
| Judicial oversight of executive agency management | Court oversight required to ensure statutory compliance | Executive prerogative to manage agencies; judicial interference improper | Dissent sees judicial intervention as creating an improper preclearance regime |
| Standard for modifying injunctions | Preliminary injunction should remain unless changed circumstances | Changed facts (RIF notices, continued statutory compliance) warrant lifting or modifying injunction | Dissent would vacate district court’s modification for abuse of discretion |
| Remedy for alleged loss of statutory service | Automatic broad injunction needed to prevent harm | Relief should be specific and only for actual, particularized injuries | Dissent favors targeted relief rather than broad injunction |
Key Cases Cited
- Adams v. Vance, 570 F.2d 950 (D.C. Cir. 1978) (appellate court can look past trial court's labels when determining effect of an order)
- Lewis v. Casey, 518 U.S. 343 (1996) (courts must not overstep into shaping executive functions)
- Norton v. Southern Utah Wilderness Alliance, 542 U.S. 55 (2004) (limits on judicial intrusion into day-to-day agency management)