Pippenger v. U.S. Doge Service

District Court, District of Columbia·Decided April 17, 2025·No. Civil Action No. 2025-1090·Published

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, 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.

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,

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].”).

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