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Commonwealth of Massachusetts v. NIH

No. 1:25-cv-10338 District · Decided
Executive order authority equitable relief

Legal Issues

Executive order authorityequitable relief
The Law · How the Case Works

Overview

Overview

A coalition of state attorneys general sued the National Institute of Health, the acting NIH Director, HHS, and the acting HHS secretary over the Trump administration's new 14% cap on overhead for federal research grants, alleging that it violates the Administrative Procedures Act. This case was consolidated with similar cases brought by the Association of American Medical Colleges and Association of American Universities.

The Issue

Issue

Whether the Trump administration's 14% overhead cap on federal research grants violates the Administrative Procedure Act and exceeds the NIH's statutory authority.

The Rules

Rule

Under the APA, agency rulemaking must follow proper notice-and-comment procedures and the resulting rule may not be arbitrary and capricious; courts review whether the agency provided a reasoned explanation and adequately addressed significant comments received.

The Application

Analysis

The consolidated plaintiffs. State attorneys general, the Association of American Medical Colleges, and the Association of American Universities. Challenged the cap as arbitrary because NIH failed to explain how reducing overhead from historical levels would affect research institutions' indirect costs, compliance capabilities, and federal grant administration without violating statutory constraints on agency discretion.

The Conclusion

Conclusion

Judge Angel Kelley decided the consolidated cases on whether the 14% overhead cap satisfies APA requirements for notice, comment, and reasoned agency action.

CourtDistrict Court, D. Massachusetts
FiledFeb 10, 2025
Judge Angel Kelley 46
CL Statusterminated
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Docket

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Outcome History (4)

  1. Feb 21, 2025 District
    TRO granted Partial relief

    District Judge Kelley extended the existing temporary restraining order to remain in effect until further order resolving the request for a preliminary injunction.

  2. Mar 5, 2025 District
    Preliminary injunction granted Full relief

    District Judge Kelley granted the motion for a preliminary injunction, enjoining the enforcement of the Supplemental Guidance to the 2024 NIH Grants Policy Statement.

  3. Apr 4, 2025 District
    Preliminary injunction granted Full relief Final

    District Judge Kelley granted the motion to convert the preliminary injunction into a permanent injunction and entered final judgment.

  4. Jan 5, 2026 Circuit
    Affirmed Partial relief Final

    U.S. Court of Appeals judgment affirming the district court's permanent injunction.

Federal Court TMR-bd742d56 Research Grant Cap Aug 5, 2026
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