On May 22, a federal judge in the Northern District of California issued a sweeping preliminary injunction blocking the federal government from moving forward with large-scale layoffs and agency reorganizations ordered under Executive Order 14210. That order, signed by President Donald Trump in February, directed agencies to submit aggressive “Reduction in Force and Reorganization Plans” — with cuts targeted at offices not “mandated by statute.”
But in American Federation of Government Employees (AFGE) v. Trump, the court found these sweeping actions went far beyond ordinary workforce adjustments. Instead, the court held, they amounted to a coordinated plan — executed through the Office of Management and Budget (OMB) and the Office of Personnel Management (OPM) — to eliminate or defund entire agency functions without congressional approval or public input.
The court called the administration’s defense a “fig leaf of agency discretion” and emphasized that “the President may not lawfully do by coordinated executive fiat what Congress has repeatedly declined to allow by statute.”
The Facts Behind the Injunction
The lawsuit was filed by a coalition of labor unions, non-profits, and local governments affected by the planned cuts. The court’s order highlighted several striking facts:
- The Department of Health and Human Services planned to lay off up to 10,000 employees across multiple components.
- The Office of Head Start shuttered its San Francisco regional office, which was responsible for distributing federal funding to thousands of children.
- The Social Security Administration initiated reorganization plans that would eliminate processing staff despite mounting backlogs.
- The Department of Veterans Affairs submitted plans to cut 83,000 positions.
All of these actions and others followed the centralized guidance of EO 14210 and implementing memos from OMB. The court found this centralization was not incidental — it was the point.
Reduction in Force (RIF) and Reorganization Plans were not agency-initiated plans developed independently. Rather, agencies were instructed to craft proposals responsive to uniform directives about which types of positions should be eliminated. These plans were then funneled through OMB and OPM, giving rise to a clear pattern: the executive branch was using administrative means to reorganize at a scale not allowed without authorization from Congress.
A Separation of Powers Violation, Not Just a Process Flaw
The court found that the executive branch was overstepping constitutional boundaries by attempting to restructure the federal government without legislation. In the past, presidents have asked Congress to authorize reorganization authority. This time, the administration attempted to proceed unilaterally — by directing each agency to submit a RIF plan aligned with centralized priorities.
The court also found that these actions likely violated the Administrative Procedure Act. Agencies failed to engage in required notice-and-comment rulemaking, and their decisions appeared arbitrary and capricious — especially where staffing cuts would make it impossible to perform core statutory functions.
For example, eliminating key processing and outreach staff in programs like Head Start and Social Security undermines the very mandates Congress assigned to those agencies. The court emphasized that agencies do not have the discretion to restructure themselves in ways that make legal compliance impossible. Nor can the executive branch, acting through OMB or OPM, issue binding requirements that amount to legislative rules without public input.
Why This Injunction Matters
This dispute is truly about whether the president can rewrite the structure of federal agencies by pressuring them to gut staff, close offices, and abandon statutory mandates. And while the government claimed these were agency-led choices, the evidence showed centralized planning, uniform guidance, and parallel action — a pattern the court could not ignore.
The injunction blocks further implementation of these reorganization plans and freezes pending layoffs across dozens of agencies. It protects not only the workers facing immediate job loss, but also the communities that rely on them — including veterans, children, seniors, and vulnerable populations who depend on public programs.
The ruling also recognizes the importance of judicial review in checking unlawful executive overreach. Had the court accepted the government’s argument that these were just run-of-the-mill personnel moves, the president could have cleared out entire agencies with no recourse, so long as the removals were laundered through existing RIF rules.
Instead, the court looked beyond labels to examine the functional reality of what was happening: not discrete employment actions, but a coordinated dismantling of agency capacity across the federal government.
Other Legal Challenges
The injunction in AFGE v. Trump is not the only legal development stemming from the administration’s sweeping civil service policies.
In DHS Probationary Employees 1 Class v. Department of Homeland Security, the Merit Systems Protection Board recently certified a nationwide class appeal challenging mass terminations of probationary employees. These terminations — nearly 370 in total — were executed over just six days in February 2025 pursuant to a directive issued by DHS’s Chief Human Capital Officer. The Board found that the class certification was appropriate and ordered additional briefing on whether the terminations constituted an unlawful RIF. If the Board finds jurisdiction, it could open the door to reinstatement or relief for hundreds of affected employees.
Meanwhile, in the District of Massachusetts, another federal court has issued a significant ruling in a consolidated case brought by 21 states, school districts, and unions including the American Federation of Teachers (AFT), AFSCME, and SEIU. There, Judge Myong J. Joun granted a preliminary injunction halting a March 2025 RIF that cut more than 2,100 employees from the U.S. Department of Education. The court found that the RIF, combined with attempts to transfer or abandon core statutory functions like student loans and special education, violated multiple constitutional and statutory provisions — including the separation of powers, the Take Care Clause, and the Administrative Procedure Act.
Judge Joun rejected the administration’s claim that the RIF was a benign reorganization, writing that the evidence pointed to a deliberate effort to dismantle the Department without Congressional authorization. The court ordered reinstatement of terminated employees and restoration of programs to preserve the agency’s statutory mandates.
In a separate case out of the District of Rhode Island, Rhode Island v. Trump, a federal court also issued a preliminary injunction halting implementation of Executive Order 14210 as it applied to the Federal Mediation and Conciliation Service (FMCS). The court found that the administration’s attempt to eliminate core FMCS programs—without statutory repeal or appropriations changes—likely violated both constitutional separation of powers and the Administrative Procedure Act. The injunction blocks the planned RIF at FMCS and preserves the agency’s mediation and conflict resolution functions through the pendency of the litigation.
What’s Next
The federal government has already appealed the preliminary injunction in AFGE v. Trump to the Ninth Circuit and is seeking emergency relief from the Supreme Court to stay the lower court’s order. The outcome of that request may determine whether agencies can resume layoffs and reorganizations while litigation continues.
For now, the preliminary injunction remains in effect. It freezes the implementation of Executive Order 14210 across dozens of agencies, protecting not just employees at risk of termination, but the public programs they serve.
The case is far from over, but the court’s message is clear: even sweeping changes must comply with the law. Structural reorganization of the federal government cannot proceed through backdoor executive planning.
