Abramowitz v. Lake (VOA injunction 2025)
Case Overview
The government appealed Judge Lamberth's preliminary injunction preventing the government from dismantling the Voice of America.
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The Application
The district court found the government likely violated applicable law governing VOA and that dismantling the agency posed irreparable harm to the public interest, weighing this against the government's claimed authority to reorganize the executive branch. Judge Lamberth concluded the preliminary injunction standards were satisfied.
The Conclusion
The district court issued a preliminary injunction on April 24, 2025. The government appealed to the D.C. Circuit, which is now reviewing whether the lower court properly applied the preliminary injunction standard.
Case Analysis
Overview
The Trump administration appealed Judge Lamberth's order granting a partial summary judgement for Michael Abramowitz which prevents Kari Lake from removing Abramowitz from his position as director of Voice of America.
Overview
The government appealed Judge Lamberth's preliminary injunction preventing the government from dismantling the Voice of America.
Issue
Whether the Trump administration has constitutional and statutory authority to remove Michael Abramowitz as Director of Voice of America, or whether federal law protects his tenure in that position.
Rule
Presidential removal authority over agency heads is limited by statute and constitutional principles; absent statutory authorization, the President may remove officials only for "good cause" or similar standards, as established in Humphrey's Executor v. United States and its progeny.
Analysis
Judge Lamberth found that statutory protections applicable to the VOA director position restrict removal authority and granted Abramowitz partial summary judgment, preventing the administration from removing him without satisfying applicable legal standards.
Conclusion
The lower court's partial summary judgment for Abramowitz remains in effect pending the Trump administration's appeal to the CADC; the case is currently active on appeal.
Notes
D.C. Circuit appeal.
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