Department of Education v. California (TRO)

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In Department of Education, et al. v. California, the Supreme Court in a per curiam decision granted the federal government’s application to stay a district court order that had mandated continued payment of certain education-related grants. The District Court for the District of Massachusetts had issued a temporary restraining order (TRO) on March 10, 2025, barring the termination of grant payments and requiring the government to pay both past-due and ongoing obligations. The lower court found that the states challenging the terminations were likely to succeed on their claims under the Administrative Procedure Act (APA). 

The Supreme Court, however, treated the TRO as a de facto preliminary injunction and concluded that the district court likely lacked jurisdiction to order monetary payments under the APA. Citing precedents such as Sampson v. Murray and Great-West Life & Annuity Ins. Co. v. Knudson, the Court emphasized that the APA does not waive sovereign immunity for claims that essentially seek money damages or enforce a contractual obligation to pay money—relief instead governed by the Tucker Act and reserved to the Court of Federal Claims. 

The Court also held that the government demonstrated a likelihood of success on appeal and that the balance of equities favored a stay. Respondents had not shown they would suffer irreparable harm, particularly because they had the resources to continue their programs and could seek recovery in another forum if successful. The Court concluded that any harm resulting from program shutdowns would be self-imposed.

Read by RJ Dieken.