Commonwealth of Massachusetts v. National Institutes of Health
Legal Issues
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Overview
Overview
The government appealed Judge Page Kelley's permanent injunction which prevents the government from implementing the research grant cap.
The Issue
Issue
Whether the government may implement a research grant cap policy without violating applicable law or constitutional protections.
The Rules
Rule
A court may grant a permanent injunction to prevent government action upon finding the movant is likely to succeed on the merits and will suffer irreparable harm absent injunctive relief. Appellate courts review such injunctions for abuse of discretion.
The Application
Analysis
Judge Page Kelley issued a permanent injunction preventing implementation of the research grant cap, finding sufficient legal or constitutional grounds. The government appealed this determination to the First Circuit Court of Appeals.
The Conclusion
Affirmed on January 5, 2026, upholding the plaintiff States' permanent injunction. The plaintiffs' relief was granted and affirmed, not denied. District Judge Angel Kelley issued the injunction; the First Circuit panel was Julie Rikelman, Kermit Lipez, and Jeffrey Howard. Mandate issued February 27, 2026.
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