# Department of Education v. California **No. 24A910 · per curiam · April 4, 2025 · 5–4** The Supreme Court's first grant-termination ruling of the second Trump term. It was a one-paragraph emergency-docket order, and it moved the fight over terminated federal grants out of the courts that could stop the terminations. ## The case In February 2025 the Department of Education cancelled about **$65 million** in Teacher Quality Partnership and SEED grants, teacher-training programs. The department cited their DEI content. Eight states sued in Massachusetts. On March 10, 2025, Judge Myong Joun issued a temporary restraining order requiring the payments to continue, and the First Circuit refused to stay it. ## The order The Court treated the government's application as a request for a stay and granted it. Its reasoning was **jurisdictional, not substantive**. A suit seeking to enforce a federal obligation to pay money under a grant is in substance a contract claim against the United States. Under the **[[Tucker Act]]**, contract claims belong in the **[[Court of Federal Claims]]**, not in a district court acting under the [[Administrative Procedure Act]]. The government was therefore likely to win on jurisdiction. - **Majority:** Thomas, Alito, Gorsuch, Kavanaugh and [[Amy Coney Barrett]]. - **Roberts** would have denied the application but wrote nothing. - **[[Elena Kagan]]** dissented alone. - **[[Ketanji Brown Jackson]]**, joined by Sotomayor, dissented separately. **What the order did not decide:** it did not hold that the terminations were lawful. Its practical effect was to send grantees to a court that can award damages after the fact but generally cannot order an agency to keep a program funded. For a terminated grantee, that difference usually decides whether it survives. ## The line it started - **[[NIH v. American Public Health Association]] (Aug 21, 2025).** Two separate 5–4 votes, with Barrett deciding both. Claims seeking money from about $783 million in terminated NIH grants went to the Court of Federal Claims. The ruling vacating NIH's termination *guidance* stayed in district court under the APA. That split, money claims in one court and policy challenges in another, is now the working rule. - **Woonasquatucket River Watershed Council v. USDA (1st Cir., Aug 7, 2026).** The appeals court upheld the ruling that the [[Executive Order 14154]] funding freeze was arbitrary and capricious, but vacated the part of the order compelling payment. - **Climate United v. Citibank (D.C. Cir. en banc, Aug 4, 2026).** By 6–4, the full court reversed a September 2025 panel ruling and let APA claims over the $20 billion Greenhouse Gas Reduction Fund proceed in district court. The government moved on Aug 6 to stay the mandate pending a petition for Supreme Court review. The underlying case went on without the money claims. On Nov 13, 2025, the district court kept the states' APA and constitutional claims and let the terminations stand. Only one source covers this. ## Why it matters This order is how most of the 2025–26 grant terminations survived in practice. It made the [[Termination for Convenience]] power in grants hard to challenge on a useful timeline. It also became one of the leading examples in the [[Shadow Docket]] debate over the Court reshaping federal policy through unexplained emergency orders. See [[How a Federal Agency Is Dismantled]]. ## See also - [[Tucker Act]] · [[Court of Federal Claims]] · [[Termination for Convenience]] · [[NIH v. American Public Health Association]] - [[Shadow Docket]] · [[Administrative Procedure Act]] · [[How a Federal Agency Is Dismantled]] · [[Federal Grant Lifecycle]]