Department of Education et al. v. California et al.
No. 24A910 · Decided April 4, 2025
Whether the Supreme Court should vacate a temporary restraining order (TRO) that enjoined the Government from terminating education-related grants and required it to make payments on those obligations. The Supreme Court stayed the District Court's temporary restraining order pending appeal, finding that the District Court likely lacked jurisdiction under the APA to order the payment of money.
ON APPLICATION TO VACATE THE ORDER ISSUED BY THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS
Parties — Petitioner: DEPARTMENT OF EDUCATION et al. · Respondent: CALIFORNIA et al.
Vote & lineupPer Curiam
Who prevailed — The petitioner (Department of Education) prevailed in obtaining a stay of the District Court's order.
The question

Whether the Supreme Court should vacate a temporary restraining order (TRO) that enjoined the Government from terminating education-related grants and required it to make payments on those obligations. The case considers whether the District Court had jurisdiction under the Administrative Procedure Act (APA) to order the payment of money. It further addresses whether the TRO's characteristics make it an appealable preliminary injunction and if a stay is warranted pending appeal.

Petitioner's argument
  • The District Court lacked jurisdiction to order the payment of money because the APA's waiver of sovereign immunity does not apply to "money damages" or when another statute forbids the relief sought.
  • Jurisdiction over suits to enforce contractual payment obligations is granted exclusively to the Court of Federal Claims under the Tucker Act, 28 U. S. C. § 1491(a)(1).
  • The Government would likely be unable to recover grant funds once they are disbursed to respondents.
  • Respondents will not suffer irreparable harm pending appeal because they can maintain their programs and recover any wrongfully withheld funds in the appropriate forum if they prevail.
Respondent's argument
  • The Department of Education's mass termination of Teacher Quality Partnership (TQP) and Supporting Effective Educator Development (SEED) grants was arbitrary, capricious, and not in accordance with law under 5 U. S. C. § 706(2)(A).
  • The abrupt loss of funding causes concrete and irreparable harm to public schools and universities, including the firing of employees and cancellation of teacher-residency programs.
  • The District Court's order merely restores the pre-existing status quo prior to the terminations.
  • The Government has not provided a meaningful explanation for the summary termination of over 100 grants.
The decision
  • The Court granted the application and stayed the District Court's order pending appeal.
  • The Court determined that while appellate courts generally lack jurisdiction over TROs, this specific order contained "hallmarks of an appealable preliminary injunction" under *Sampson v. Murray* and *Abbott v. Perez*.
  • It reasoned that the Government is likely to succeed in showing the District Court lacked jurisdiction to order money payments under 5 U. S. C. § 702, which excludes "money damages."
  • The Court noted that the APA's waiver of sovereign immunity does not apply if any other statute that grants consent to suit expressly or impliedly forbids the relief sought.
  • It held that orders to "enforce a contractual obligation to pay money" fall under the Tucker Act, 28 U. S. C. § 1491(a)(1), which grants jurisdiction to the Court of Federal Claims (*Great-West Life & Annuity Ins. Co. v. Knudson*).
  • The Court distinguished this from *Bowen v. Massachusetts*, finding that the District Court's order specifically sought the enforcement of payment obligations rather than a general setting aside of agency action.
  • Regarding equities, the Court found respondents failed to refute the Government's representation that it would likely not recover funds once disbursed.
  • The Court concluded respondents would not suffer irreparable harm because they can maintain their programs and later recover funds if they prevail, citing *Cuomo v. NRC*.
Separate opinions
ROBERTS, dissenting, joined by nobody
  • Would deny the application.
KAGAN, dissenting, joined by nobody
  • Argues that *Great-West Life & Annuity Ins. Co. v. Knudson* is an inapplicable authority because it did not involve a claim brought under the APA.
  • Contends that no emergency demanded immediate intervention and the dispute should have proceeded through ordinary litigation channels.
JACKSON, dissenting, joined by SOTOMAYOR
  • Argues the TRO is non-appealable as it is expressly time-limited under Fed. Rule Civ. Proc. 65(b)(2) and does not present a threat of "potentially unlimited" duration under *Sampson v. Murray*.
  • Asserts that terminating TQP and SEED grants (authorized by 20 U. S. C. §§ 1021, 1022a, and 6672) was arbitrary and capricious under the APA, 5 U. S. C. § 706(2)(A), as it relied on factors Congress did not intend the agency to consider (*Motor Vehicle Mfrs. Assn. of United States, Inc. v. State Farm Mut. Auto. Insurance Co.*).
  • Argues that the balance of equities favors respondents due to concrete harms to teacher training programs and public schools.