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Association of American Universities v. Department of Health and Human Services

No. 25-1345 Circuit · Decided Decided
Court
1st Cir.
ca1
Decided
Jan 5, 2026
Filed
Apr 9, 2025
Filed (CL)
Apr 9, 2025
CL Status
terminated

Case Overview

The government appealed Judge Page Kelley's permanent injunction which prevents the government from implementing the research grant cap.


The Application

History

The district court found the research grant cap lacked adequate statutory authorization and violated protected interests of universities and researchers, granting a permanent injunction against implementation. The government appealed this decision to the First Circuit.

The Conclusion

The First Circuit affirmed the permanent injunction, finding the research grant cap unlawful and beyond executive authority. The executive action remains enjoined from implementation.

Outcome History (4)

  1. Jan 5, 2026 Circuit
    Affirmed Relief denied Final

    Judgment affirmed.

  2. Jan 9, 2026 Circuit
    Other Neutral

    Motion to withdraw Attorney Courtney L. Dixon as counsel for Appellants granted.

  3. Jan 12, 2026 Circuit
    Other Neutral

    Motion to withdraw Attorney Brian C. Lea as counsel for Appellants denied without prejudice.

  4. Feb 9, 2026 Circuit
    Other Neutral

    Motion to withdraw Attorney Brian C. Lea as counsel for Appellants granted.

Federal Court TMR-24aa79a3 Research Grant Cap <br> Appeal of 1:25-cv-10346, 1:25-cv-10340, 1:25-cv-10338 May 18, 2026

Case Analysis

Issue

Whether an executive action imposing a research grant cap on federal funding violates the Administrative Procedure Act or constitutional limits on executive power.

Rule

Under the APA, agency action must be supported by statutory authority and rational basis; permanent injunctions are warranted when the moving party demonstrates likelihood of success on the merits and irreparable injury.

Analysis

The district court found the research grant cap lacked adequate statutory authorization and violated protected interests of universities and researchers, granting a permanent injunction against implementation. The government appealed this decision to the First Circuit.

Conclusion

The First Circuit affirmed the permanent injunction, finding the research grant cap unlawful and beyond executive authority. The executive action remains enjoined from implementation.

Overview

The government appealed Judge Page Kelley's permanent injunction which prevents the government from implementing the research grant cap.

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