NIH Terminated 2,291 Research Grants — Judge Called It Void and Illegal

Beginning in February 2025, the Trump administration directed the National Institutes of Health to terminate hundreds of active research grants targeting topics it had declared disfavored, including diversity, equity, and inclusion research, gender identity, vaccine hesitancy, and COVID-19 studies. NIH ultimately canceled 2,291 active grants, withdrawing $2.45 billion in research funding in a matter of weeks. On April 2, 2025, researchers and health organizations filed a federal lawsuit in the U.S. District Court for the District of Massachusetts challenging the terminations as unlawful under the Administrative Procedure Act.

The case is American Public Health Association v. National Institutes of Health, Case No. 1:25-cv-10787 (D. Mass.), with a parallel appeal docketed as No. 25-1611 in the U.S. Court of Appeals for the First Circuit. In June 2025, U.S. District Judge William Young declared the NIH directives “void and illegal.” In August 2025, the Supreme Court issued a split ruling: allowing the grant terminations to stand pending appeal while leaving the underlying NIH directives vacated. As of June 2026, the First Circuit appeal is pending and Phase 2 proceedings continue in district court.

NIH Grants Termination Lawsuit Timeline and Updates

January 20, 2025 — Trump Takes Office, Executive Orders Target DEI

On Inauguration Day, President Trump signed a series of executive orders targeting diversity, equity, and inclusion programs across the federal government. Executive Order 14151, “Ending Radical and Wasteful Government DEI Programs and Preferencing,” directed all federal agencies to terminate DEI policies, programs, and preferences. A separate executive order defined sex as binary and immutable, targeting gender identity research and programs. These orders became the administrative basis for the NIH grant terminations that followed within weeks.

February–March 2025 — NIH Begins Mass Terminations

Beginning in February 2025, NIH program officers received internal directives identifying categories of research to be terminated. Topics on the termination list included DEI in health research, gender identity and transgender health outcomes, vaccine hesitancy, climate change, and COVID-19 research. NIH sent boilerplate termination letters to grant recipients stating that the research “no longer effectuates agency priorities” or was “unscientific” or harmful. Many letters were identical across hundreds of unrelated research projects. On March 26, 2025, a formal list of research categories no longer supported by the agency was distributed to NIH grant management specialists. NIH had previously awarded nearly $850 million in grants to approximately 600 ongoing COVID-19 research projects; it was not initially clear which would be canceled.

April 2, 2025 — APHA Lawsuit Filed in Massachusetts

On April 2, 2025, the American Public Health Association, Ibis Reproductive Health, the United Automobile Aerospace and Agricultural Implement Workers union, and four individual research scientists filed a lawsuit in the U.S. District Court for the District of Massachusetts. Plaintiffs were represented by CSPI’s Litigation Department, the ACLU, the ACLU of Massachusetts, the Protect Democracy Project, and Emery Celli Brinckerhoff Abady Ward and Maazel LLP.

The complaint identified five claims under the Administrative Procedure Act: the NIH directives and resulting terminations were arbitrary and capricious; not in accordance with law; exceeded statutory authority; contrary to the Fifth Amendment; and constituted unlawful withholding of action on grant applications. Plaintiffs also alleged the directives were void for vagueness under the Fifth Amendment and violated the separation of powers by effectively amending Congressional mandates without legislative action. The lawsuit noted that under statutes including the Public Health Service Act, the Minority Health and Health Disparities Research and Education Act of 2000, and the 21st Century Cures Act, Congress had explicitly mandated NIH to conduct health equity research and recruit underrepresented groups into biomedical research. The executive orders could not override those statutory directives.

April 4, 2025 — Multistate AG Lawsuit Filed

On April 4, 2025, California Attorney General Rob Bonta co-led a coalition of 16 state attorneys general in filing a second lawsuit against NIH and HHS in the same Massachusetts district court, before Judge Young. The coalition challenged both the grant terminations and the underlying executive orders under the APA. The states argued that the terminations were unlawful and that federal agencies cannot simply refuse to disburse congressionally appropriated funds based on presidential preference.

April 25, 2025 — Motion for Preliminary Injunction Filed

Plaintiffs filed a motion for preliminary injunction seeking an immediate court order halting further terminations and restoring the canceled grants. At a May 22 hearing, Judge Young indicated he would consolidate the preliminary injunction motion with an expedited trial on the merits of the APA claims, treating the government’s opposition as a motion to dismiss. The government argued, among other things, that the UAW lacked standing to sue on behalf of its researcher members.

May 30, 2025 — Judge Young’s Mixed Ruling on Motion to Dismiss

On May 30, 2025, Judge Young partially granted and partially denied the government’s converted motion to dismiss. He dismissed the two constitutional claims, including the Fifth Amendment and void-for-vagueness counts, without prejudice. He denied the government’s argument that the UAW lacked standing, ruling that the union could represent graduate students, postdoctoral researchers, and faculty members whose grants had been terminated.

June 16, 2025 — Judge Young Strikes Down NIH Directives at Trial

Judge Young held a Phase 1 merits hearing on June 16, 2025. After two hours of argument and a recess, he ruled from the bench that the NIH directives and resulting grant terminations were unlawful and would be set aside as arbitrary and capricious under the APA. His ruling quoted from the administrative record, describing the termination letters as “bereft of reasoning, virtually in their entirety.” He found that NIH had failed entirely to consider the reliance interests of researchers, universities, graduate students, and the broader public in the continuity of federally funded research. He commented that the directives and terminations reflected racial and anti-LGBTQ discrimination, stating he had not seen government racial discrimination like this in 40 years on the bench. Judge Young was appointed to the federal bench in 1985 by President Ronald Reagan.

June 23–25, 2025 — Judgment Issued, NIH Ordered to Halt Terminations

On June 23, 2025, Judge Young issued a Partial Final Judgment declaring the NIH directives “of no effect, void, illegal, set aside, and vacated” under the APA, and declaring the resulting grant terminations equally void. That same day, the government filed a notice of appeal and moved to stay the judgment. Judge Young denied the stay on June 24. On June 25, a senior NIH official sent an internal memo instructing all agency staff: “Effective immediately, please do not terminate any additional grant projects. Please unrelease all grant projects that are in the cue to be terminated.” NIH began reinstating terminated grants.

July 2, 2025 — 103-Page Opinion and Order

On July 2, 2025, Judge Young issued a 103-page written opinion detailing his findings of fact and conclusions of law. The opinion explained in full why the directives and terminations were arbitrary, capricious, and not in accordance with law, and why they violated Congressional mandates to fund health equity research and diversify the biomedical workforce.

July 3–18, 2025 — First Circuit Denies Stay

The government moved the U.S. Court of Appeals for the First Circuit on July 3 to stay the judgment pending appeal. A First Circuit panel unanimously denied the motion on July 18, finding that the government had not met its burden for a stay. The panel did not decide the merits of the appeal.

July 24, 2025 — Government Applies to Supreme Court for Emergency Stay

Having failed at both the district court and the First Circuit, the government filed an emergency application for a stay with the U.S. Supreme Court on July 24, 2025, on the Court’s emergency docket. Plaintiffs filed their opposition on August 1.

August 21, 2025 — Supreme Court Issues Split 5-4 Ruling

The Supreme Court issued its ruling on August 21, 2025, in National Institutes of Health v. American Public Health Association, No. 25A103. In a 5-4 decision, the Court granted a partial stay. The Court declined to stay the district court’s vacatur of the NIH directives, meaning those directives remain “of no effect” and cannot be used as the basis for future terminations. However, the Court stayed the district court’s vacatur of the individual grant terminations, allowing those specific canceled grants to remain canceled during the appeal. The Court held that the district court likely lacked jurisdiction to review individual grant terminations under the APA, because the Tucker Act gives the U.S. Court of Federal Claims jurisdiction over contract-based claims against the federal government. The majority indicated that individual grant termination challenges must be filed at the Court of Federal Claims. The stay applied to approximately $783 million in terminated grants at issue in the APHA case. Justices Thomas, Alito, Gorsuch, Kavanaugh, and Barrett voted for the partial stay. Justices Sotomayor, Kagan, Jackson, and Roberts dissented from the stay of the grant termination vacatur.

October–December 2025 — First Circuit Briefing Completed

The government filed its corrected appellant brief in the First Circuit on October 10, 2025. Plaintiffs filed their answering brief on November 12. The government filed its reply brief on December 4. The appeal presented two central questions: whether the district court correctly found the directives and terminations arbitrary and capricious under the APA, and whether the district court had jurisdiction to vacate the grant terminations given the Tucker Act.

December 29, 2025 — Parties Reach Stipulation on Grant Applications

On December 29, 2025, the parties filed a joint stipulation and proposed order in the district court. The government agreed that NIH would individually evaluate and complete review on a list of over 5,000 pending grant applications that had been paused, rejected, or denied under the challenged directives, using NIH’s ordinary scientific review process without applying the executive directives. On December 29, NIH issued 528 grant decisions, of which 499 were approvals.

January 6, 2026 — District Court Grants Stipulation; First Circuit Oral Argument

On January 6, 2026, Judge Young granted the proposed stipulation order and dismissed without prejudice the Phase 2 claims in the complaint that the stipulation resolved. On the same day, oral arguments on the appeal were heard before the First Circuit. Plaintiffs argued the district court had correctly found the NIH directives and terminations arbitrary and capricious and that the court had jurisdiction. The government argued that jurisdiction lay with the Court of Federal Claims and that the directives were within the executive branch’s lawful authority to set research priorities.

What the NIH Terminations Actually Affected

The 2,291 terminated grants were not randomly distributed across NIH’s portfolio. Research published in the Proceedings of the National Academy of Sciences in March 2026 documented the demographic patterns. Early-career investigators, including assistant professors, postdoctoral scholars, trainees, and graduate students, were disproportionately affected. Women-led projects were overrepresented among the cancellations, with women accounting for nearly 60% of canceled assistant professor grants and 60% of canceled doctoral candidate grants.

More than 150 training grants for students and junior scientists, many specifically designed to increase workforce diversity in the biomedical field, were among those canceled. NIH unpublished nearly 100 Notices of Funding Opportunity covering health disparities, workforce diversity, and research with sexual and gender minorities. The economic impact extended beyond the terminated grants themselves. NIH economic multiplier models suggest each dollar of federal research funding generates several additional dollars in economic activity. The $2.45 billion in withdrawn funding represented not just canceled projects but disrupted careers, abandoned graduate theses, terminated postdoctoral positions, and lost institutional investment.

The Legal Framework: APA, Tucker Act, and Where These Cases Now Stand

The case has exposed a significant and unresolved tension in federal administrative law. The APA allows federal courts to set aside agency action that is arbitrary, capricious, or not in accordance with law. Judge Young found that the NIH directives easily met that standard. The termination letters were boilerplate. They provided no individualized analysis. They cited no specific deficiency in the terminated research. They ignored reliance interests. By any conventional APA standard, they were textbook arbitrary action.

The Tucker Act complicates the remedy. That statute gives the U.S. Court of Federal Claims jurisdiction over contract claims against the federal government. The Supreme Court’s August 2025 ruling indicated that federal research grants may be contracts, meaning challenges to specific termination decisions belong in the Court of Federal Claims, not in federal district courts. The district court has jurisdiction over challenges to the directives themselves, but whether it can reinstate individual terminated grants is now in legal dispute.

The practical consequence: the NIH directives remain vacated. NIH cannot use them as the basis for new terminations. But the grants already terminated under those directives remain canceled pending the First Circuit’s ruling on the jurisdictional question and the merits. Researchers who lost specific grants and want monetary relief may need to file individual claims in the Court of Federal Claims under a contract theory.

What the Trump Administration’s Defense Actually Argued

The government’s legal defense rested on two pillars. First, it argued the executive branch has inherent authority to set research priorities and direct agency funding decisions. The president may decide that certain topics are inconsistent with current policy without providing individualized justification for each grant. Second, it argued that federal district courts lack jurisdiction over grant terminations under the Tucker Act, regardless of how the terminations were decided.

Neither argument addressed the underlying facts. The government never contested that the termination letters were boilerplate. It never argued that any of the terminated grants had failed to comply with their terms, or that there was cause to terminate any specific grant. Its defense was structural and procedural: the right body to bring these claims is elsewhere, and the executive’s policy choices are not subject to APA review in district court. Judge Young found the first argument unpersuasive on the merits. The Supreme Court took the jurisdictional argument more seriously.

What This Means for Researchers Whose Grants Were Terminated

As of June 2026, researchers whose grants were canceled face a complicated landscape. The NIH directives that produced the terminations are vacated and cannot be reapplied. New grant applications covering the affected topics must be reviewed under NIH’s ordinary scientific standards, per the December 2025 stipulation. But the 2,291 previously terminated grants remain canceled. Reinstatement of those specific grants depends on the First Circuit’s ruling and any subsequent Supreme Court proceedings.

Researchers seeking reinstatement of their specific terminated grants may have a path through the U.S. Court of Federal Claims if those grants can be characterized as contracts. That is a new and uncertain litigation avenue that few researchers have yet pursued. The ACLU and co-counsel have not announced a separate Court of Federal Claims action as of the most recent publicly available filings.

The parallel multistate lawsuit and the APHA suit addressed similar legal theories. The DOJ grant cancellations lawsuit and the AmeriCorps funding restoration lawsuit both involve the same underlying pattern: the executive branch cutting congressionally appropriated funds mid-stream, without statutory authority, prompting federal courts to order restoration. The NIH case is the largest and most legally complex of these funding disputes.

What This Lawsuit Teaches Consumers

The NIH grants termination lawsuit is not a consumer case in the traditional sense. No product failed. No company overcharged a customer. What failed was the executive branch’s obligation to follow its own regulations, honor Congressional mandates, and apply basic administrative procedure to decisions affecting billions of dollars in research.

The administrative law dimension is accessible: federal agencies cannot terminate programs they do not like simply by issuing boilerplate letters. They must explain their reasoning. They must consider reliance interests. They must act within the authority Congress gave them. When they fail to do those things, federal courts can intervene under the APA. That is what happened here.

The Supreme Court’s jurisdictional ruling adds a layer that matters for anyone watching how the government handles federal grants going forward. If grant terminations are contracts, and contract disputes belong in the Court of Federal Claims, then the APA route for challenging them in district court is narrowed. Researchers, universities, and advocacy organizations tracking this case closely will be watching the First Circuit’s ruling to understand what legal avenues remain open for challenging politically motivated grant cancellations in the future.