Funding Freeze

This page catalogs executive orders, federal agency directives, litigation updates and other guidance and information pertaining to the freeze of funds for research grants.

Purdue Post Award will continue to monitor award and payment activity on a case-by-case basis and review status with Principal Investigators as needed.

Latest News

• Preliminary Injunction in place. Purdue Post Award will continue to monitor award and payment activity on a case-by-case basis and review status with Principal Investigators as needed.

Litigation Summary

National Association of Diversity Officers in Higher Education v. Trump

• February 3 2025, Complaint alleging freeze violates spending clause, is void for vagueness (e.g., does not define key terms such as DEI, DEIA), and violates First Amendment.
• February 21, 2025, Court Order and supporting Memorandum granting in part and denying in part plaintiff’s motion by granting a preliminary injunction that holds under January 20, 2025, EO Ending Radical and Wasteful Government DEI Program and Preferencing Sec. 2(b)(i) (“Termination Provision”), January 21, 2025, EO Ending Illegal Discrimination and Restoring Merit-Based Opportunity Sec. 3(b)(iv) (“Certification Provision”) and Sec. 4(b)(iii) Enforcement provision, government cannot:
  • pause, freeze, impede, block, cancel, or terminate any awards, contracts or obligations (“Current Obligations”), or change the terms of any Current Obligation, on the basis of the Termination Provision;
  • require any grantee or contractor to make any “certification” or other representation pursuant to the Certification Provision; or
  • bring any False Claims Act enforcement action, or other enforcement action, pursuant to the Enforcement Threat Provision, including but not limited to any False Claims Act enforcement action premised on any certification made pursuant to the Certification Provision.
• The government appealed the preliminary injunction and sought a stay during the appeal.  The Court denied the stay.
• March 3, 2025, Memorandum Opinion and Order clarifying that “enjoined parties” includes defendants other than the President, as well “as all other federal executive branch agencies, departments, and their heads, officers, agents, and subdivisions.”
• March 13, 2025, Emergency Motion from the Plaintiff reporting widespread violations of the preliminary injunction and requesting that Court schedule an emergency status conference to evaluate Dept. of Justice’s efforts to ensure the government complies.  Court ordered a status conference on Mar. 14, 2025.
• 4th Circuit’s grant of the government’s motion to stay the preliminary injunction, pending a decision on the government’s appeal of the preliminary injunction.  Accordingly, the preliminary injunction will no longer be in effect while the 4th Circuit considers the government’s appeal.
• March 21, 2025, the Plaintiff’s filed a motion to vacate the preliminary injunction and dismiss the pending appeal  so that Plaintiffs could proceed for additional relief in the District Court.  The government opposed this motion, and the District Court held a hearing on the motion on April 10. 

State of New York v. Trump

• January 28, 2025,  Complaint alleging that freeze violates APA and separation of powers. 
• February 10, 2025, Temporary Restraining Order (TRO)
• February 10, 2025, Government Appeal of TRO to First Circuit Court of Appeals
• February 11, 2025, Denial of Appeal from First Circuit Court of Appeals
• February 14, 2025, Court Order finding government did not follow original TRO and ordering immediate restoration of frozen funding and end of funding pause while TRO is pending.
• March 6, 2025, Memorandum and Order granting a preliminary injunction enjoining defendants from pausing, freezing, blocking, canceling, suspending, terminating, or otherwise impeding disbursement of appropriate federal funds to the States under awarded grants, executed contracts, other executed financial obligation.
• The government appealed the preliminary injunction to the First Circuit Court of Appeals.
• The government filed a status report detailing its compliance with preliminary injunction, and the plaintiffs filed a response contesting the report and contending that the government continues to fail to comply with the preliminary injunction.  The plaintiff’s filed a motion to enforce the Preliminary Injunction on March 24, 2025.  
• On March 27, 2025, the 1st Cir. Court of Appeals denied the government’s motion for a stay of the preliminary injunction pending appeal. 
• Apr. 4, 2025, Order granting the Plaintiff’s motion for enforcement of the preliminary injunction.  The Court held that FEMA’s manual review process for processing payments on awards violated the preliminary injunction and ordering FEMA to immediately cease this process and comply with the preliminary injunction’s mandate “not to pause or otherwise impede the disbursement of federal funds based on the funding freezes required or implied by the Executive Orders at issue. 
• April 7, 2025, Text Order of the Court temporarily staying its enforcement of the preliminary injunction that it issued on Feb. 25, 2025, based on Supreme Court’s April 4, 2025, order in State of CA. v. Dept. of Education (see above) while the court considers the government’s motion for reconsideration. 

National Council of Nonprofits v. Office of Management and Budget

• January 28, 2025, Complaint alleging freeze violates APA and is contrary to the First Amendment.
• February 3, 2025, Temporary Restraining Order. 
• February 25, 2025, Order granting a Preliminary Injunction and accompanying Memorandum Opinion.  “Government is enjoined from giving effect to, or reinstating under a difference name, the unilateral, non-individualized directives in OMB Memorandum M-25-13 with respect to disbursement of Federal funds under all open awards.” Also requires Government to give notice of this preliminary injunction to agencies and instruct them to continue releasing disbursement on open awards.
• March 4, 2025, Motion to Clarify Scope of Preliminary Injunction filed by plaintiffs asking court to clarify whether court requirement that renew disbursement of funds “under all open awards” means “all” open awards, as plaintiffs contend, or “only open awards that have been partially disbursed” as the government contends. Defendants have opposed the motion for clarification. The court denied this motion because plaintiffs did not take issue earlier with the government’s interpretation of “open awards” as “only open awards that have been partially disbursed.”