United States Conference of Catholic Bishops v. United States Department of State
Civil Action No. 2025-0465
D.D.C.Mar 11, 2025Background
- The United States Conference of Catholic Bishops (USCCB) has long partnered with the government to provide refugee resettlement services, funded by annual cooperative agreements with the Department of State's PRM.
- For FY25, the Conference received two contracts worth ~$65 million total, covering both general refugees and Afghan special immigrant visa holders.
- On January 20, 2025, President Trump issued an executive order pausing foreign aid, immediately prompting the State Department to suspend and then terminate the Conference's contracts, citing shifting agency priorities.
- The Conference had millions in outstanding reimbursement requests and claimed that terminating funding endangered refugee support; it sued, seeking a temporary restraining order and preliminary injunction to force continued payment and contract performance.
- The government argued that this was a contract dispute exclusively within the jurisdiction of the Court of Federal Claims (per the Tucker Act), not the district court.
- The district court denied the preliminary injunction, ruling it lacked jurisdiction to grant such contractual relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| District Court Jurisdiction under APA vs. Tucker Act | The APA waives sovereign immunity; equitable relief is appropriate for agency action undoing the contract | All contract-based claims must go to the Claims Court under the Tucker Act, not district court | District court lacks authority—contract-based claims must go to Claims Court |
| Nature of Remedy Sought (Equitable vs. Contractual) | Framed as equitable relief under APA (set aside agency action, reinstate funding) | Relief sought is specific performance/money due under a contract; sounds in contract | Remedy is contractual (specific performance/payment), not available in equity from this court |
| Artful Pleading to Avoid Tucker Act | Conference says claims are under federal statutes, not contract per se | The relief and claims still stem from contracts; creative pleading does not sidestep Tucker Act | Claim is essentially contractual regardless of pleading, so bar applies |
| Irreparable Harm / Preliminary Injunction Standard | Loss of funding will irreparably harm refugees and the Conference | No irreparable harm; court also lacks authority regardless of harm | Court cannot decide merits—lacks jurisdiction to reach preliminary injunction standard |
Key Cases Cited
- Munaf v. Geren, 553 U.S. 674 (preliminary injunction is extraordinary relief)
- Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (preliminary injunction standard)
- Nken v. Holder, 556 U.S. 418 (merging balance of equities and public interest)
- Spectrum Leasing Corp. v. United States, 764 F.2d 891 (district court lacks jurisdiction for specific performance/contract remedies, Tucker Act applies)
- Ingersoll-Rand Co. v. United States, 780 F.2d 74 (Claims Court has exclusive jurisdiction for contract termination disputes with the government)
- Megapulse, Inc. v. Lewis, 672 F.2d 959 (case turns on nature of relief sought and source of right for contract vs. general federal law jurisdiction)
- Sharp v. Weinberger, 798 F.2d 1521 (no jurisdiction to compel government to fulfill its contracts in district court)