DAVID WILLIAMS, еt al., Plaintiffs, v. NATIONAL AERONAUTICS AND SPACE ADMINISTRATION, et al., Defendants.
Case No. 26-cv-564 (CRC)
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
May 12, 2026
(Partially-Redacted Version of ECF No. 24)
Only a few months before the Artemis II mission opened the door to future lunar and deep-space exploration, the National Aeronautics and Space Administration (“NASA“) closed another door here on Earth. Namely, in late 2025, NASA ceased in-person services at the agency‘s largest research library located on the campus of the Goddard Space Flight Center (“GSFC“) in Greenbelt, Maryland. It also initiated a 60-day assessment of the library collection to determine which materials would be preserved by the agency and suspended access to the NASA Space Science Data Coordinated Archive (the “Database“), a permanent archive for space mission documentation.
Plaintiffs in this case—two NASA-affiliated scientists and a labor organization representing federal employees at GSFC—filed this lawsuit against NASA, the NASA Administrator, and the Archivist of the United States. They allege that NASA‘s decision to shutter the Goddard Library and take the Database offline violates the Federal Records Act (“FRA“) and the Administrative Procedure Act (“APA“). Plaintiffs now move for a temporary restraining order and/or preliminary injunction, warning of the “imminent threat” that federal records and unique materials in the Goddard Library collection will be permanently lost unless
I. Background
Before turning to the specifics of Plaintiffs’ motion for preliminary injunctive relief, the Court first surveys the relevant legal and factual background.
A. Legal Background
The FRA is a series of statutes that “govern[] the creation, management[,] and disposal of federal records.” Armstrong v. Bush (Armstrong I), 924 F.2d 282, 284 (D.C. Cir. 1991); see also Am. Friends Serv. Comm. v. Webster, 720 F.2d 29, 36 (D.C. Cir. 1983) (explaining that the FRA “establish[es] a unified system for handling the ‘life cycle’ of federal records—covering their creation, maintenance and use, and eventually their disposal by either destruction or deposit for preservation“). Congress enacted the FRA to ensure “(1) efficient and effеctive records management; (2) accurate and complete documentation of the policies and transactions of the Federal Government; and (3) judicious preservation and disposal of records.” Armstrong I, 924 F.2d at 284–85 (alterations and internal quotation marks omitted) (quoting
1. Preservation of Federal Records
To ensure the preservation of federal records, the FRA “burdens the heads of federal agencies with several obligations.” Armstrong v. Exec. Off. of the President, Off. of Admin. (Armstrong II), 1 F.3d 1274, 1278 (D.C. Cir. 1993) (per curiam); see Kissinger v. Reps. Comm. for Freedom of Press, 445 U.S. 136, 147 (1980). Broadly speaking, agency heads must “make and preserve records containing adequate and proper documentation of the organization, functions, policies, decisions, procedures, and essential transаctions of the agency[.]”
“Because [the] FRA is primarily directed at the preservation of federal records, the crux of the statute lies in its disposal provisions.” Competitive Enter. Inst., 67 F. Supp. 3d at 26. Put simply, an agency may not “alienate[] or destroy[] records” unless provided by the FRA.
all recorded information, regardless of form or characteristics, made or received by a Federal agency under Federal law or in connection with the transaction of public business and preserved or appropriate for preservation by that agency or its legitimate successor as evidence of the organization, functions, policies, decisions, procedures, operations, or other activities of the United States Government or because of the informational value of data in them.
If a document is a “record,” then the FRA “prohibits an agency from discarding it by fiat.” Armstrong II, 1 F.3d at 1278 (citing Webster, 720 F.2d at 62). Instead, the Archivist must approve an agency‘s disposal of any record. See id. at 1279; Competitive Enter. Inst., 67 F. Supp. 3d at 27. An agency may obtain the Archivist‘s approval “in one of two ways.” Armstrong II, 1 F.3d at 1279. First, the agency may “submit a schedule of records sought to be discarded to the Archivist.” Id. If the Archivist concludes that the records do not have “sufficient administrative, legal, research, or other value to warrant their continued preservation by the Governmеnt,” then he may “empower the agency to dispose of those records” after providing public notice and an opportunity to comment.
2. Enforcement Scheme
In addition to the safeguards described above, the FRA “sets forth a structure whereby the Archivist and agency heads are to work together to ensure that no documents are unlawfully destroyed.” Jud. Watch, Inc. v. Tillerson, 293 F. Supp. 3d 33, 37 (D.D.C. 2017), aff‘d sub nom. Jud. Watch, Inc. v. Pompeo, 744 F. App‘x 3 (D.C. Cir. 2018). Relevant here, the agency head is required to “notify the Archivist оf any actual, impending, or threatened unlawful removal, defacing, alteration, corruption, deletion, erasure, or other destruction of records in the custody of the agency[.]”
If the agency head “ignores this statutory mandate,” the Archivist must step in. Price v. DOI, No. 18-cv-1339 (CRC), 2019 WL 2526439, at *4 (D.D.C. June 19, 2019). Specifically, if the agency head does not initiate action through the Attorney General “within a reasonable period of time” or “is participating in, or believed to be participating in” the unlawful action, the Archivist must ask the Attorney General to initiate a recovery action and notify Congress once the request has been made.
3. NASA‘s Records Schedules
Per the FRA, NASA has issued a policy directive requiring employees to “[i]dentify, preserve, and protect records, including temporary records, permanent records, and vital records, against loss, theft, unauthorized release or change[.]” NASA Policy Directive 1440.61 § 1(a)(2) (Sep. 10, 2014), https://perma.cc/VE8Q-7AWU. With the Archivist‘s approval, the agency has also adopted a series of records retention schedules. See Compl. ¶ 7 & n.1; NASA Records Retention Schedules (“NRRS“) (Sep. 3, 2025), https://perma.cc/D9DV-QZNB. Plaintiffs’
The NASA Archival Collections Schedule—which is part of the broader NRRS—applies to NASA‘s “archival collections,” which are “created and maintained for preservation and access to materials that the agency considers historically, technologically, scientifically, culturally, and/or intrinsically significant.” Opp‘n, App. 1 at 4. Under the schedule, NASA must retain the records “indefinitely . . . until no longer needed or [the] dissolution of the agency/agency archival program.”
B. Factual Background
Plaintiffs’ motion for preliminary relief encompasses three related components of NASA‘s operations: the Goddard Library, the materials within the library, and the Database.
1. The Goddard Library
NASA operates 20 “centers” and “facilities” across the United States, including GSFC. Declaration of Gary Willis (ECF No. 18-1) (“Willis Decl.“) ¶ 5. GSFC is the agency‘s “largest
The Goddard Library, which “has historically functioned as NASA‘s largest research library,” is located within Building 21 of GSFC‘s Greenbelt campus. Moton Decl. ¶ 4. Thе library houses approximately 127,000 items, including books, journals, reference materials, technical reports, oversize documents, atlases, and other media. See Willis Decl. ¶ 48. Among these items are “unique, copyrighted, and out-of-print records and materials, many of which have not been digitized and are unavailable anywhere else.” Moton Decl. ¶ 4.
Like many other federal workers, NASA employees “are now more likely to use electronic library research services and resources,” and they “rel[y] on physical libraries less and less.” Willis Decl. ¶ 8. Nevertheless, at least some current and former NASA employees have routinely used the Goddard Library‘s physical space and materials to conduct research, restore datasets, and consult with librarians. See, e.g., Declaration of Dr. David Williams (ECF No. 3-1) (“Williams Decl.“) ¶¶ 6, 10–13; Declaration of Dr. Giovanni De Amici (ECF No. 3-3) (“De Amici Decl.“) ¶¶ 4–7, 10.
In recent years, NASA leadership has sought to “make better use of the space” at GSFC. Declaration of Raymond J. Rubilotta (ECF No. 8-3) (“Rubilotta Decl.“) ¶ 14. By February 2022, NASA had developed plans for a large “transformation” of the Greenbelt campus, which included “constructing new spaces, renovating some facilities, divesting or partially divesting other spaces, and demolishing a number of other facilities.”
In August 2025, however, President Trump signed an executive order titled “Further Exclusions from the Federal Labor-Management Relations Program.” See Exec. Order 14343, 90 Fed. Reg. 42683 (Aug. 28, 2025).1 The executive order determined that the Federal Service Labor-Management Relations Statute did not apply to NASA because the agency has “as a primary function intelligence, counterintelligence, investigative, or national security work.”
As the Greenbelt campus transformation continued in late 2025, GSFC leadership decided that Building 21 should “be adapted for a new use.”
While NASA leadership dеbated how to repurpose the Goddard Library‘s physical space, GSFC initiated a “60-day assessment” of the library collection in December 2025. Willis Decl. ¶ 25. During this assessment, a team of trained librarians determined which library materials would be retained by NASA and which would be “dispositioned” by the General Services Administration (“GSA“).
The team concluded the assessment in January 2026.
3. The Database
The Database “serves as [NASA‘s] centralized repository of scientific data and mission documentation that enables ongoing research, validation, anomaly resolution, and future mission design.” Moton Decl. ¶ 7. While the Database is “administratively distinct” from the Goddard Library, Plaintiffs submit that they are “functionally inseparable.” Williams Decl. ¶ 7 (explaining that “[t]he Goddard Library functions as a ‘Rosetta Stone’ for raw data kept in the Database“).
C. Procedural History
Plaintiffs filed this lawsuit in February 2026. Their complaint alleges that NASA‘s decisions to close the Goddard Library, destroy some materials within the library, and “permanently shutter” the Database violate the FRA and APA and amount to ultra vires agency action. See Compl. ¶¶ 79–139. A few days later, Plaintiffs simultaneously moved for a temporary restraining order and preliminary injunction, citing the “imminent threat” that NASA‘s actions would cause the “irreversible loss of federal records and unique materials amassed by [the agency] over decades and entrusted to the Goddard Library and Database for preservation, access, mission continuity, and safety.” Pls.’ Emergency Mot. for TRO & Prelim. Inj. (“Pls.’ Mot.“) at 3. The Court promptly convened a scheduling conference, during which Defendants represented that (1) NASA took the Database offline for security reasons and does not intend to delete it; (2) the materials that NASA sends to Glenn will not be destroyed; and
II. Legal Standards
A temporary restraining order and preliminary injunction are “extraordinary remed[ies] that should be granted only when the party seeking the relief, by a clear showing, carries the burden of persuasion.” Postal Police Officers Ass‘n v. U.S. Postal Serv., 502 F. Supp. 3d 411, 418 (D.D.C. 2020) (Cooper, J.) (quoting Cobell v. Norton, 391 F.3d 251, 258 (D.C. Cir. 2004)). “The same standard governs both types of preliminary relief.”
Plaintiffs’ motion seeks four forms of relief. First, Plaintiffs ask the Court to enjoin NASA from “carrying out any disposition, destruction, shredding, dispersal, reclassification, transfer, commingling, or other irreversible alteration of federal records and research materials” associated with the Goddard Library and the Database. Pls.’ Mot. at 2. Second, they ask that NASA and the Archivist maintain and preserve the “provenance and chain-of-custody” of any materials that have already been boxed or moved.
A. Closure of the Goddard Library
Plaintiffs’ complaint alleges that NASA‘s decision to close the Goddard Library violates the APA. See Compl. ¶¶ 110–32. Specifically, they contend that the closure was arbitrary and capricious because the agency (1) “fail[ed] to consider or explain the abandonment of prior commitments” to keep the library open in the 2012 settlement agreement with GESTA, and (2) “fail[ed] to consider . . . the institutional, operational, and statutory interests previously recognized by NASA itself in committing to maintain centralized physical library resources.”
Plaintiffs are not entitled to preliminary relief on this claim because they have not established irreparable harm arising from the Goddard Library‘s closure. See Chaplaincy of Full Gospel Churches v. England, 454 F.3d 290, 297 (D.C. Cir. 2006) (“A movant‘s failure to show any irreparable harm is . . . grounds for refusing to issue a preliminary injunction, even if the other three factors entering the calculus merit such relief.“). “[T]he basis of injunctive relief in the federal courts has always been irreparable harm and inadequacy of legal remedies[.]” Sampson v. Murray, 415 U.S. 61, 88 (1974) (citation omitted). The D.C. Circuit “has set a high standard for irreparable injury.” England, 454 F.3d at 297. The injury “must be both certain and great; it must be actual and not theoretical.”
Plaintiffs’ allegations of irreparable harm focus exclusively on the potential loss of records from the Goddard Library, not the closure of the physical library space in Building 21. For example, Plaintiffs’ describe an “active packing-and-removal operation at the Goddard Library.” Pls.’ Mot. at 13. They maintain that this “mass removal event” constitutes irrеparable harm because “[o]nce such materials are dispersed, discarded, or stripped of provenance, neither Plaintiffs nor the Court can later reconstruct the collection or its contextual integrity through a merits ruling.”
Put simply, Plaintiffs have not explained how NASA‘s plans to repurpose the Goddard Library space would cause irreparable harm if they could still access the materials that were once housed there. See Sierra Club v. EPA, 793 F. Supp. 3d 158, 164 (D.D.C. 2025) (recognizing that “[m]ere injuries, however substantial, in terms of money, time, and energy necessarily expended
B. Materials Removed from the Goddard Library
Plaintiffs are primarily concerned about the “disposition or destruction” of records in the Goddard Library that they allege “will cause permanent, unrecoverable loss.” Pls.’ Mot. at 6. As noted above, they seek two forms of preliminary relief based on their “FRA-via-APA” claims. Price, 2019 WL 2526439, at *4. First, they request an injunction that would, among other things, bar NASA from “carrying out any disposition” of materials from the Goddard Library and compel the agency to produce an inventory of the materials slated for removal. Pls.’ Mot. at 3. Second, they ask the Court to order the NASA Administrator and Archivist to perform their “nondiscretionary” duty to notify the Attorney General about the “actual, impending, or threatened unlawful destruction or removal” of records from the Goddard Library.
To assess the relief that Plaintiffs сould obtain at this preliminary stage, the Court must first define the scope of judicial review under the FRA. The statutes themselves do not provide a cause of action for private parties to recover records unlawfully removed by an agency. See Kissinger, 445 U.S. at 148; Competitive Enter. Inst., 67 F. Supp. 3d at 31 (“[P]rivate litigants cannot state a claim for legal relief under [the] FRA.“). However, this circuit has recognized that “in some cases, the APA can provide a jurisdictional hook for a suit alleging noncompliance with the FRA.” CREW v. Pruitt, 319 F. Supp. 3d 252, 257 (D.D.C. 2018) (emphasis omitted). In Armstrong I, the D.C. Circuit considered three types of private actions: a “direct private action[] to require that agency staff comply with the agency‘s recordkeeping guidelines“; a claim that the agency‘s “recordkeeping guidelines and directives are arbitrary and capricious“; and a claim that the agency head and Archivist “breached the statutory duty to take enforcement action” through the Attorney General. 924 F.2d at 297. The court concluded that the first type of claim was not reviewablе, but the latter two were. See
First, the court found that “it would clearly contravene [the FRA‘s] system of administrative enforcement to authorize private litigants to invoke federal courts to prevent an agency official from improperly destroying or removing records.” Armstrong I, 924 F.2d at 294 (citing Congress‘s decision to “strengthen the administrative enforcement mechanism rather than explicitly sanction[] litigation at the behest of private citizens“). In other words, “challenges to the agency‘s day-to-day implementation” of its recordkeeping guidelines are “unreviewable.” Competitive Enter. Inst., 67 F. Supp. 3d at 32 (explaining that the FRA bars “any judicial assessment of agency compliance in specific factual contexts“); see also CREW v. Wheeler, 352 F. Supp. 3d 1, 11 (D.D.C. 2019) (“The APA does not grant federal courts the authority to engage
Second, the circuit concluded that a private party may bring an APA challenge to the sufficiency of the agency‘s “recordkeeping guidelines and dirеctives,” including a claim that they “do not adequately describe the material that must be retained as ‘records’ under the FRA.” Armstrong I, 924 F.2d at 293; see Pruitt, 319 F. Supp. 3d at 258. A private party may challenge either an agency‘s “formal policies” or its “informal practices.”9 Am. Oversight, 788 F. Supp. 3d at 21. To evaluate whether an agency‘s recordkeeping guidelines pass muster under the APA, courts consider “whether they adequately explain the factors that agency staff should consider in deciding whether specific [materials] are records.” Armstrong I, 924 F.2d at 297 n.14. This assessment focuses on the sufficiency of the guidelines, not how the agency has applied them in practice. See
Third, Armstrong I held that “if the agency head or Archivist does nothing while an agency official destroys or removes records in contravention of agency guidelines and directives,” then a private party may “bring suit to require the agency head and Archivist to
Working within this framework, the Court turns to Plaintiffs’ specific claims for preliminary injunctive relief.
2. Review of the NASA Archival Collections Schedule
Plaintiffs seek an injunction preventing NASA from “implementing or carrying out” its planned disposition of the Goddard Library materials and requiring the agency to “maintain and preserve, under litigation hold, the provenance and chain-of-custody of any materials” processed by its team of librarians.10 Pls.’ Mot. at 2. To justify this requested relief, Plaintiffs contend that the NASA Archival Collections Schedule—which took effect in September 2025—is arbitrary and capricious, see
As explained above, “courts may not entertain private suits alleging that agencies have improperly destroyed or removed records, but they may consider ones challenging whether agency guidelines that permit destruction of certain records are adequate under the FRA[.]”
a. Challenges to the NASA Archival Collections Schedule
Consider first the APA challenges to the NASA Archival Collections Schedule itself. See Armstrong I, 924 F.2d at 291 (recognizing that district courts may assess whether an agency‘s recordkeeping policies violate the APA “because they permit the destruction of ‘records’ that must be preserved under the FRA“). Plaintiffs’ complaint appears to challenge the broader NRRS, which contains numerous records schedules. See Compl. ¶¶ 7 & n.1 (citing the full NRRS), 79–87 (Count I alleging that Defendants’ approval and implementation of the NRRS was an arbitrary and capricious agency action), 88–94 (Count II alleging that NASA and the Archivist exceeded their statutory authority by approving and implementing the NRRS), 103–09 (Count IV alleging that the NRRS was “approved and implemented without observance of procedure required by law“). This broadside attack on the NRRS also forms the basis of Plaintiffs’ motion for preliminary injunctive relief. See, e.g., Pls.’ Mot. at 9 (“[T]he court would almost certainly find the implementation of the [NRRS] to be arbitrary and capricious.“), 12 (“Plaintiffs аre likely to succeed on their claims that the [NRRS] unlawfully shifts appraisal and preservation determinations and dilutes safeguards required by the FRA and applicable NARA regulations[.]“). However, Plaintiffs have since narrowed the scope of their challenge, clarifying that their APA claims pertain only to the NASA Archival Collections Schedule. See Reply Br. at
The problem is that Plaintiffs have not explained how the NASA Archival Collections Schedule is deficient under the FRA. To be sure, the complaint broadly alleges that NASA‘s records schedules “eliminated or materially diluted mandatory safeguards governing the identification and preservation of historically significant and research-valuable records during mass disposition events.” Compl. ¶ 81. It further contends that the schedules authorize NASA to determine “in the first instance . . . whether records warrant continued preservation.”
This shortcoming distinguishes Plaintiffs’ request from America First Legal Foundation v. Becerra, No. 24-cv-1092 (RC), 2024 WL 3741402 (D.D.C. Aug. 9, 2024), a case in which another court in this district granted a preliminary injunction based on an agency‘s deficient recordkeeping policy. In Becerra, the plaintiff challenged a Centers for Disease Control and Prevention (“CDC“) policy that authorized the deletion of its employees’ emails within a few months after they left the agency. See
Unlike in Becerra, Plaintiffs have not explained how the Archivist-approved NASA Archival Collections Schedule is “unlаwful or inadequate” under the FRA. 2024 WL 3741402, at *12. Accordingly, there is not a sufficient basis to grant the requested injunction.
b. Challenges to the Sorting of the Goddard Library Collection
In their reply brief and at oral argument, Plaintiffs change course and attack the means by which NASA sorted the Goddard Library collection. Plaintiffs describe the Goddard Library as a “mixed collection” containing both records and non-records. Reply Br. at 4–6. They then fault the agency for not following the “records-governance steps” that they claim are necessary to preserve records under the FRA.
This argument runs headlong into Armstrong I and its progeny, which make clear that private litigants may not bring suit to “enjoin agency actions in contravention of agency [recordkeeping] guidelines.” 924 F.2d at 294. Challenges to the propriety of NASA‘s “records disposal decisions” during the Goddard Library sorting process are “prohibited” under both the FRA and the APA. Competitive Enter. Inst., 67 F. Supp. 3d at 33. If such claims were actionable, the Court would need to “impermissibly inject [itself] into the ‘details of record management,’ a task better left ‘to thе discretion of agency heads.‘” CREW v. Pompeo, 2020 WL 1667638, at *5 (quoting Armstrong I, 924 F.2d at 293). Because the FRA does not invite judicial review of a NASA records schedule “as implemented” to the Goddard Library collection, see Reply Br. at 8, the Court cannot grant Plaintiffs’ request for preliminary relief, see Am. Oversight, 788 F. Supp. 3d at 24–25 (finding that a plaintiff was not entitled to a preliminary injunction for claims based on isolated instances of agency officials deleting records in violation of the FRA).
Plaintiffs next request an injunction compelling the NASA Administrator and Archivist to fulfill their obligations under the FRA to “protect records from actual, impending, or threatened unlawful destruction or removal” through “referral to the Attorney General and notification to Congress.” Pls.’ Mot. at 3 (citing
Plaintiffs have failed to make that showing. Assuming arguendo that the first two requirements are satisfied, Plaintiffs have not demonstrated that the NASA Administrator and Archivist knew the agency was violating the FRA by sorting the Goddard Library collection in the way it did. As this Court has previously explained, neither an agency head nor the Archivist has a duty to act under
In Price, this Court addressed a motion for preliminary relief based on a similar “failure-to-act § 3106” claim.
The Court then recognized that a “finding of a violation” is a “condition precedent” to another FRA provision requiring the Archivist to take enforcеment action, and “it would make little sense to read § 3106 differently[.]”
Plaintiffs have not established that predicate here. The complaint makes the conclusory allegation that that “[t]he Archivist was . . . on notice that records housed at the Goddard Library include records of unique historical and research value and that closure of the library posed an imminent risk of unlawful destruction, dispersal, or irreversible loss of such records.” Compl. ¶ 99. Plaintiffs’ motion for preliminary injunctive relief only briefly addresses § 3106, noting that “a rapid mass review and active dismantling of a records repository” is an “‘actual, impending, or threatened’ unlawful destruction or removal that triggers notification requirements” under the statute.11 Pls.’ Mot. at 13. And at oral argument, Plaintiffs’ counsel submitted that both the NASA Administrator and the Archivist should have been “on notice” that the sorting process may have violated the FRA based on “the nature of the review, the time span, [and] the amount of materials that the agency needed to move through.” Rough Hr‘g Tr. 20:17,
But recall that “[a] preliminary injunction is an extraordinary remedy that should be granted only when the party seeking the relief, by a clear showing, carries the burden of persuasion.” Cobell, 391 F.3d at 258 (citing Mazurek v. Armstrong, 520 U.S. 968, 972 (1997)). While Plaintiffs repeatedly allege that the 60-day assessment poses a hypothetical—yet unspecified—risk that federal records may be destroyed, they have not provided evidence that “either the [NASA Administrator] or the Archivist found an actual, threatened, or impending unlawful removal or destruction of records.”12 Price, 2019 WL 2526439, at *14. Because they have not “show[n] that the condition precedent to § 3106‘s mandatory duties has been satisfied,” Plaintiffs have not established a likelihood of success on their failure-to-act § 3106 claim.
* * *
Because Plaintiffs have not shown a likelihood of success on the merits of their “FRA-via-APA” claims, they are not entitled to а preliminary injunction.13
C. Taking the Database Offline
In addition to their claims about the Goddard Library‘s physical space and the materials once housed within it, Plaintiffs allege that the decision to “permanently close[]” the Database was arbitrary and capricious. See Compl. ¶¶ 110–32. In turn, their motion for preliminary injunctive relief asks the Court to order that Defendants not destroy or irreversibly alter the Database while the litigation is ongoing. See Pls.’ Mot. at 2.
As noted above, Defendants have since provided a declaration which clarifies that the Database was taken offline temporarily for security reasons, and it will remain offline [REDACTED]. See Simon Decl. ¶¶ 3–5. In the meantime, the material on the Database is being held [REDACTED], and no material relevant to this litigation has been removed.
Because Plаintiffs have failed to show that the Database‘s temporary “offline” status—which preserves the Database material—would cause irreparable harm, the Court denies Plaintiffs’ motion for a preliminary injunction on that claim as well. See England, 454 F.3d at 297.
For the foregoing reasons, the Court will deny Plaintiffs’ [3] Emergency Motion for Temporary Restraining Order and Preliminary Injunction. A separate Order shall accompany this memorandum opinion.
CHRISTOPHER R. COOPER
United States District Judge
Date: May 12, 2026