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President Donald Trump attends the 157th National Memorial Day Observance at Arlington National Cemetery, Monday, May 26, 2025, in Arlington, Va. (AP Photo/Jacquelyn Martin).

The Trump administration achieved a significant win on Thursday when a federal court in Maryland upheld the Department of Education’s (DOE) plan to reduce a particular workforce segment.

In a 13-page memorandum opinion, U.S. District Judge Stephanie A. Gallagher—first nominated by Barack Obama and later appointed by President Donald Trump—dismissed attempts to halt mass layoffs at the Institute of Education Sciences (IES) through a preliminary injunction.

In early April, two professional associations representing educational researchers sued the DOE over a “reduction-in-force” (RIF) that cut 90% of staff at the IES. The 47-page complaint also took issue with what the plaintiffs termed “a thoughtless and sweeping cancellation of contracts” supporting “intensive studies” on various education methods as well as “data collection and dissemination.”

In late April, the plaintiffs moved for injunctive relief, requesting the court reverse the RIF, rehire the fired employees, reinstate the canceled contracts and affirmatively stop the government from destroying any of the data the IES had previously collected.

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The court, in rejecting the injunction request, said, “The record in this case underscores that it is poorly suited for preliminary relief.”

“In asking this Court to order the government to reinstate a large number of employees without any information about which employees performed critical statutory functions and which did not, Plaintiffs again seek an overbroad mandatory injunction,” Gallagher wrote in the opinion. “Plaintiffs have not shown they have standing to seek that relief.”

In a memorandum supporting the injunction request, the plaintiffs argued they had organizational, or associational, standing — a somewhat disfavored concept under current U.S. Supreme Court jurisprudence, which often falls prey to government challenges.

“Plaintiffs are membership associations of education researchers,” the 53-page memo argued. “These researchers face, and are already experiencing, innumerable harms as a result of IES’s destruction.”

The government for its part, in a 31-page memorandum of law in opposition, argued the plaintiffs had failed to offer specific facts that at least one of their identified members had suffered or would suffer actual or imminent and concrete harm — reciting the elements required to sustain the organizational theory of standing.

“Plaintiffs’ theory of standing amounts to a causal chain of reductions-in-force and contract cancellations that plaintiffs allege will impair the Department from providing the information Plaintiffs’ members seek,” the government’s motion argued. “That is insufficient to confer standing.”

The victory for the Trump administration here is the latest iteration of a by-now familiar judicial tactic — rejecting a plaintiff’s claims using the analytical framework widely understood by legal scholars as “conservative standing doctrine.”

This judicial theory was created in two cases from the 1920s by conservative judges who sought to restrain the use and limits of constitutional redress. In other words, standing doctrine was created — and has over time been honed and sustained — to limit lawsuits against the government. While technically procedural in nature, as opposed to relying on the underlying merits arguments in a dispute, standing arguments tend to be fact-intensive.

The court makes clear, however, that the plaintiffs have failed to prove significant harm that warrants a preliminary injunction.

In her opinion, Gallagher insisted the inquiry so far has not been on the merits, that the record in the case is insufficient, and that she believes the plaintiffs might stand a chance down the line.

“Plaintiffs seem to be right that, today, IES is not doing a number of tasks Congress requires of it,” the opinion reads. “And they may well be right that IES is unlikely to fulfill many of its statutory functions in the future. The Court likewise takes Plaintiffs at their word that not receiving data they expected to receive will harm them.”

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