We've seen the Trump administration score some legal wins on President Donald Trump's agenda and executive orders in the appellate courts. But wins at the district court level have been few and far between. On Friday, however, the administration scored a significant win in two companion cases involving the dismantling of the United States Agency for International Development (USAID), as D.C. District Court Judge Carl Nichols ruled in favor of the administration on jurisdictional grounds.
Both the American Foreign Services Association (AFSA) and the Personal Services Contractor Association (PSCA) sued the administration in February over Executive Order 14169 ("Reevaluating and Realigning United States Foreign Aid"), asserting that the executive action violates the separation of powers and the Administrative Procedures Act, and seeking injunctive relief. Judge Nichols, a Trump appointee, initially granted AFSA's motion for a temporary restraining order (TRO) in part, but shortly thereafter denied it and later denied their motion for a preliminary injunction. In March, he denied PSCA's TRO motion as well.
READ MORE: Judge Presses Pause on Trump Administration's Planned Downsize of USAID Workforce
NEW: Judge Says 'No' to USAID Workers Seeking TRO Over Contract Terminations
In Friday's ruling, Judge Nichols denied the plaintiffs' motion for summary judgment (basically a request for him to enter judgment in their favor on the merits) and granted the administration's motion to dismiss in the AFSA case, and in the PSCA case, he denied the plaintiffs' motion for preliminary injunction. His reasoning in both was that he/the court lacks proper jurisdiction over the claims before him. In other words, he exercised judicial restraint, something we've seen sorely lacking at the district court level of late:
The Court ultimately cannot reach the merits of any plaintiff’s allegations, however, because it concludes that it lacks jurisdiction over the claims of AFSA, AFGE, and Oxfam (which have moved for summary judgment after the Court denied their earlier motion for a preliminary injunction), and that it likely lacks jurisdiction over the claims of the PSCA (which has moved for a preliminary injunction). The Court will accordingly grant the government’s motion to dismiss the AFSA case and will deny the PSCA’s motion for a preliminary injunction.
...
As to AFSA and AFGE, which represent USAID employees, the Court explained at length when denying the preliminary injunction that the Civil Service Reform Act (CSRA), Federal Service Labor-Management Relations Statute (FSLMRS), and Foreign Service Act (FSA) likely channel their members’ claims to various agencies and provide for subsequent review in specific Article III courts.
...
What the Court is ultimately most moved by, then, are the same jurisdictional principles that form the core of these cases. It is likely that the only harms as to which the PSCA has standing to seek relief are those regarding the termination of its members’ voluntarily entered contractual agreements with USAID, and it is also likely that such terminations must and be addressed (and, if unlawful, will be redressed) under the CDA. See Widakuswara II, 2025 WL 1288817, at *5. On the other hand, issuing preliminary relief requiring the reinstatement of PSCs would intrude into Executive Branch personnel matters and expand the judicial role. See id. at *5–6 (“[T]he Executive Branch has a significant interest in maintaining control over personnel matters” and “[t]he public has an interest in the Judicial Branch’s respect for the jurisdictional boundaries laid down by Congress.”). Where the PSCA has not demonstrated any irremediable injury and where Congress meanwhile has “limited the resolution of . . . potentially costly [personnel] claims” implicating the public fisc to “specialized tribunals” like the Court of Federal Claims, id. at *6, the Court concludes that neither the equities nor the public interest favor a preliminary injunction.
So, yes, this is a win for the administration, but it has larger implications beyond just these two cases. Margot Cleveland explains:
Reason this is key is because many other cases against Trump Administration raise similar claims and the holding of no jurisdiction would bar those claims too. Once appealed, the circuit court's precedent will bind other DC district courts & will be persuasive in other cases.
And if disputes continue, SCOTUS will resolve which will bind all lower courts.
As Cleveland rightly notes, this ruling is square on the issue of whether the district courts even have jurisdiction in many of these cases, and this will propel the issue up before the D.C. Circuit Court of Appeals, which has already hinted at finding they do not in some of its rulings regarding stays. If the Circuit agrees that the district courts do not have jurisdiction for these sorts of claims, that binds the rest of the D.C. district judges. And when/if the issue is forced to the Supreme Court, that will resolve it once and for all as to all of the lower courts. Now, there's no guarantee that's how the appellate courts will rule, but as noted, their rulings thus far on the motions/applications for stay they've been presented certainly appear to hint at that.
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