Pippenger v. U.S. Doge Service

CourtDistrict Court, District of Columbia
DecidedApril 17, 2025
DocketCivil Action No. 2025-1090
StatusPublished

This text of Pippenger v. U.S. Doge Service (Pippenger v. U.S. Doge Service) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pippenger v. U.S. Doge Service, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

SASHA PIPPENGER, et al.,

Plaintiffs, Civil Action No. 25-cv-1090 (BAH) v. Judge Beryl A. Howell U.S. DOGE SERVICE, et al.,

Defendants.

MEMORANDUM AND ORDER DENYING TEMPORARY INJUNCTIVE RELIEF

Seven plaintiffs, who include former employees, program partners, a current personal

services contractor, and a donor of the U.S. Institute of Peace (“USIP”), sued the U.S. DOGE

Service (“DOGE”), several DOGE (or DOGE-affiliated) officials (including the current

President of USIP, Nate Cavanaugh), the existing ex officio members of USIP’s Board of

Directors, President Trump, White House staffer Trent Morse, the Office of Personnel

Management, the General Services Administration (“GSA”), the Department of State, as well as

USIP itself (collectively, “defendants”). Am. Compl. ¶¶ 6-30, ECF No. 9. Their claims arise out

of the same set of alleged facts at issue in U.S. Institute of Peace v. Jackson, No. 25-cv-804,

namely, President Trump’s termination of USIP’s appointed Board members, the replacement of

USIP’s president by three remaining ex officio members, the subsequent transfer of USIP’s

headquarters and other assets to GSA, the termination of the majority of USIP’s employees, and

broad termination of its contracts and programming. See generally Am. Compl.; Am. Compl.,

USIP v. Jackson, 25-cv-804, ECF No. 12. As in the prior related case, plaintiffs here allege that

USIP “is an independent non-profit organization” not subject to executive branch control. Am.

Compl. ¶¶ 1, 32, 136 (describing USIP as an “independent nonprofit corporation”); Am. Compl.

1 ¶¶ 1, 6, 30, 75, 77, USIP v. Jackson, 25-cv-804. Plaintiffs assert, in five claims, that defendants

acted ultra vires and in violation of the USIP Act’s statutory removal protections when removing

USIP’s former Board members, Am. Compl. ¶¶ 135-44, 156-72 (Counts 1, 3), that they violated

the APA by acting arbitrarily and capriciously when seizing control of USIP assets, id. ¶¶ 145-

55, (Count 2), that they violated the APA by attempting to cease USIP’s activities and effectively

shut it down, id. ¶¶ 156-72 (Count 3), that they acted ultra vires and violated the USIP Act and

other statutory mandates in doing the same, id. ¶¶ 173-76 (Count 4), and that they violated

separation of powers by engaging in all of these acts, id. ¶¶ 177-183 (Count 5).

Plaintiffs moved for a temporary restraining order (“TRO”) on April 14, 2025, seeking an

injunction directing a host of actions by defendants, including: (1) prohibiting (a) USIP, its

Endowment, its Board, and its officers from transferring any assets out of USIP or the

Endowment; (b) USIP, its Board, and its officers from terminating any further employees,

personal service contractors, or contracts; (c) defendants from publishing or disclosing the

identity of any current or former employees, grantees, program partners, or personal service

contractors; (2) restoring all terminated USIP employees and personal service contractors to their

roles in a paid leave status so they can retain their benefits during litigation; and (3) transferring

ownership of USIP’s headquarters—which were previously transferred by defendant Cavanaugh,

as president of USIP, to GSA—back to USIP. Pls.’ Mot. for TRO (“Pls.’ Mot.”) at 14, ECF No.

11; Pls.’ Proposed Order, ECF No. 11-18. Plaintiffs also requested that the TRO include

declarations that the former Board members were terminated unlawfully and that all subsequent

actions after removal of those Board members were ultra vires, violated the APA, and violated

separation of powers. See Pls.’ Proposed Order. Defendants opposed. See Defs.’ Opp’n, ECF

No. 18.

2 After providing an opportunity for defendants to submit briefing explaining their

opposition to plaintiffs’ claims, see Minute Order (Apr. 14, 2025), this Court held a hearing on

the motion for a TRO on April 16, 2025. In response to the Court’s queries about the scope of

the requested relief, plaintiffs requested an opportunity to supplement their papers in support of a

more limited TRO, and after the hearing, plaintiffs timely filed a new proposed order, narrowing

their request for relief. See Pls.’ Notice Following Hr’g, Amended Proposed Order, Ex. A, ECF

No. 21-1. Specifically, plaintiffs no longer request the inclusion in the TRO of any declarations,

nor an injunction barring the publication or disclosure of identities of people affiliated with USIP

and termination of any USIP employees or contracts (apart from personal service contractors,

whose termination plaintiffs still wish to be enjoined), nor an injunction requiring the transfer of

USIP headquarters back to USIP. They narrowed their request regarding future property

transfers to an order prohibiting transfers of USIP assets to GSA or the Department of the

Treasury. Defendants timely filed their response to plaintiffs’ supplemental submission earlier

today. See Defs.’ Resp. to Pls.’ Notice Following the Hearing on the TRO, ECF No. 22.

Upon consideration of the current record, the parties’ initial and supplemental

submissions and arguments presented at the TRO motion hearing, plaintiffs’ motion is denied for

the reasons explained below.

I. LEGAL STANDARD

For a TRO to be granted, a plaintiff must demonstrate the following: (1) the plaintiff is

likely to succeed on the merits of its claims; (2) the plaintiff is likely to suffer irreparable harm

without the TRO; (3) the balance of the equities favors issuance of the TRO; and (4) the issuance

of a TRO is in the public interest. Ramirez v. Collier, 595 U.S. 411, 421 (2022) (quoting Winter

v. Nat. Res. Def. Council, 555 U.S. 7, 20 (2008)). When the government is the opposing party,

3 the final two factors, the balance of the equities and the public interest, merge into one. Karem v.

Trump, 960 F.3d 656, 668 (D.C. Cir. 2020).

The likelihood of success on the merits factor is the most important, and absent such a

showing, relief should be denied. See, e.g., Greater New Orleans Fair Hous. Action Ctr. v. U.S

Dep’t of Hous. & Urban Dev., 639 F.3d 1078, 1088 (D.C. Cir. 2011) (“When a plaintiff has not

shown a likelihood of success on the merits, there is no need to consider the remaining factors.”);

Hanson v. District of Columbia, 120 F.4th 223, 242-43 (D.C. Cir. 2024) (“[W]e hold [appellant]

is not sufficiently likely to succeed on the merits of his claim to warrant the entry of

a preliminary injunction against enforcement of the [law].”).

To show a likelihood of success on the merits, and for the Court to have jurisdiction over

plaintiffs’ motion, plaintiff must also demonstrate that plaintiff has standing. “In the context of”

temporary injunctive relief, the plaintiff must “show a substantial likelihood of standing under

the heightened standard for evaluating a motion for summary judgment,” thus requiring more

than mere allegations. Elec. Privacy Info. Ctr. v. Presidential Advisory Comm’n on Election

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