E.K. v. Department of Defense Education Activity

CourtDistrict Court, E.D. Virginia
DecidedJuly 11, 2025
Docket1:25-cv-00637
StatusUnknown

This text of E.K. v. Department of Defense Education Activity (E.K. v. Department of Defense Education Activity) is published on Counsel Stack Legal Research, covering District Court, E.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
E.K. v. Department of Defense Education Activity, (E.D. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division E.K. and S.K., minors, by and through their ) parent and next friend Lindsey Keeley, etal., ) ) Plaintiffs, ) ) v. ) Civil Action No. 1:25-cv-637 (PTG/IDD) ) DEPARTMENT OF DEFENSE EDUCATION ) ACTIVITY, et al., ) ) ) Defendants. ) MEMORANDUM ORDER This matter comes before this Court on Defendants’ Motion for Reconsideration of this Court’s June 3, 2025 Order for Defendants to produce a list of library books currently under review within the Department of Defense. Dkt. 41. First, Defendants contend that the preliminary injunction posture constrains the Court’s review to only the necessary factual record, rather than any additional facts “neither party has identified to be necessary to resolving the pending motion.” Dkt. 42 at 4-6. Second, Defendants assert that the deliberative process privilege shields disclosure of the list because it is both pre-decisional and deliberative. Jd. at 7-12. Plaintiffs opposed Defendants’ motion. Dkt. 44. To aid its review of the motion, the Court granted Defendants’ request to file the list of removed books ex parte for the Court’s in camera review. Having considered the parties’ submissions and reviewed the list in camera, the Court finds that privilege does not shield disclosure of Defendants’ list of books. Furthermore, the Court finds that the list is appropriately part of the factual record for the motion for preliminary injunction. Accordingly, the Court will deny Defendants’ Motion for Reconsideration.

Background Plaintiffs are twelve students of military families at five Department of Defense Education Activity (‘DoDEA”) schools who bring First Amendment claims against Defendants DoDEA, Dr. Beth Schiavano-Narvaez, Director of DoDEA, and Peter Brian Hegseth, Secretary of Defense, in connection with their changes to curricular material and removal of library books at DoDEA schools. Dkt. 1 (“Compl.”) §§ 4, 10-15. Plaintiffs allege that Defendants’ actions—done in implementation of various Presidential Executive Orders allegedly targeting gender ideology, “discriminatory equity ideology,” and anti-American sentiments in the federal government— violate their Free Speech rights. /d. J] 51, 83-101. On May 7, 2025, Plaintiffs filed a motion for preliminary injunction seeking to enjoin “Defendants from enforcing Executive Order Nos. 14168, 14185, and 14190 and related memoranda, directives, and guidance in DoDEA schools.” Dkt. 10 at 25. The motion further requests the Court to order the Government to “return[] all books and curriculum already quarantined or removed based on potential violation of the Executive Orders to their preexisting shelves, classrooms, and instructional units.” /d. at 26. The parties completed briefing on the matter. See Dkts. 10, 29, 36. On June 3, 2025, this Court held a hearing on the motion for preliminary injunction. In both their briefing and at the hearing, Plaintiffs have repeatedly stated that they have requested the list of books removed from DoDEA libraries to no avail and instead have “compiled the current reported list of books removed . . . through their own observation.” Dkt. 10 at 8; see also Dkt. 47 (“Tr.”) at 7:24-8:1, 14:12-13, 16:19-25. Consequently, the Court ordered that Defendants submit information available regarding the centralized list of removed books to the Court and to Plaintiffs. Tr. at 32:17-33:3. On June 6, 2025, Defendants moved for a six-day extension to produce the list of library books, which the Court subsequently granted. Dkts. 38, 40. On June 11, 2025,

Defendants filed the instant Motion for Reconsideration. Dkt. 41. Defendants proposed that, in the alternative, the Court could conduct an in camera review of the list ex parte to adjudicate the privilege issues or “stay its order to produce the list until the motion for reconsideration has been resolved.” Dkt. 42 at 12. On June 16, 2025, the Court issued an order permitting Defendants to produce the list of books ex parte for in camera review. Dkt. 45. Defendants filed the list ex parte that same day. Legal Standard While Federal Rules of Civil Procedure 59(e) and 60(b) govern motions for reconsideration of final judgments, Rule 54(b) applies to reconsideration of interlocutory orders. Fayetteville Invs.

v. Comm. Builders, Inc., 936 F.2d 1462, 1469-70 (4th Cir. 1991); Nicholas v. Wyndham Intern., Inc., 373 F.3d 537, 541 (4th Cir. 2004) (“Discovery orders are ‘inherently interlocutory.” (quoting McCook Metals LLC v. Alcoa, Inc.,249 F.3d 330, 335 (4th Cir. 2001))). “Motions for reconsideration of interlocutory orders are not subject to the strict standards applicable to motions for reconsideration of a final judgment.” Am. Canoe Ass’n v. Murphy Farms, Inc., 326 F.3d 505, 514 (4th Cir. 2003). Rather, a district court retains discretion to “reconsider and modify its interlocutory judgments . . . at any time prior to final judgment.” /d. at 514-15; see also Fayetteville Invs., 936 F.2d at 1469.! To guide their discretion over Rule 54(b) motions, courts in the Fourth Circuit look to the legal framework for Rule 59 and Rule 60 motions for reconsideration. Am. Canoe Ass'n, 326 F.3d at 515; Orbcomm Inc. v. Calamp Corp., 215 F. Supp. 3d 499, 503 (E.D. Va. 2016) (relying on the

| The Fourth Circuit has held that “a district court’s otherwise broad discretion to reconsider interlocutory orders is narrowed in the context of motions to reconsider issues going to the court’s Article III subject matter jurisdiction.” Am. Canoe Ass’n, 326 F.3d at 515. However, no Article III jurisdictional questions are raised here.

standards of Rule 59 and 60 even though “the Fourth Circuit has declined to ‘thoroughly express [its] views on the interplay of Rules 60, 59 and 54.’” (quoting Am. Canoe Ass'n, 326 F.3d at 515)). Therefore, even with Rule 54(b) motions for reconsideration, courts generally “do not depart from a previous ruling unless ‘(1) a subsequent trial produces substantially different evidence, (2) controlling authority has since made a contrary decision of law applicable to the issue, or (3) the prior decision was clearly erroneous and would work manifest injustice.” Orbcomm Inc., 215 F. Supp. 3d at 503 (quoting Am. Canoe Ass’n, 326 F.3d at 515). Generally, “[a]bsent a significant change in the law or the facts,” a court will grant a motion for reconsideration only where it “has patently misunderstood a party,” “made a decision outside the adversarial issues presented to the Court by the parties, or has made an error not of reasoning but of apprehension.” Evans v. Trinity Indus., Inc., 148 F. Supp. 3d 542, 544 (E.D. Va. 2015) (quoting United States v. Smithfield Foods, Inc., 969 F. Supp. 975, 977 (E.D. Va. 1997)). Discussion Defendants contend that reconsideration of the Court’s Order for the list of removed books is warranted for two reasons. Dkt. 42 at 1. First, Defendants assert that “this Court cannot enlarge the factual record” to consider the list of books at the preliminary injunction phase. Jd. at 4. Second, Defendants invoke the deliberative process privilege over the list of books, which they claim is pre-decisional and deliberative and therefore protected from disclosure. /d. at 6.

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E.K. v. Department of Defense Education Activity, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ek-v-department-of-defense-education-activity-vaed-2025.