Timeline of Key Developments Related to Recent Executive Actions as of March 12, 2025

On Tuesday, March 4, 2025, President Trump addressed a joint session of Congress, and highlighted many of the actions his administration has taken during his first six weeks in office.  This timeline highlights key developments pertaining to recent executive orders (“EOs”) and other executive actions issued by the second Trump administration.  It focuses on issues most relevant to federal contractors and grant recipients, and is divided into five topics: (1) Federal Funding; (2) DEI and Gender; (3) Energy and Environment; (4) Trade and Foreign Aid; and (5) DOGE and Federal Workforce.  Covington’s Government Contracts Practice is continuing to track these and other developments and will plan to periodically update this timeline.

This document provides a high-level summary of recent events and is not exhaustive. In addition, this document was last updated on the date provided above.  To the extent you may have questions regarding any of the developments discussed below — or other matters — please reach out to a member of Covington’s Government Contracts Practice.

1.     Federal Funding

• January 20: President Trump signed various EOs pausing federal funding, or directing agencies to terminate contracts and grants that are contrary to the Administration’s policies. These include:
  • EO 14154, “Unleashing American Energy,” which, among other things, directed an immediate pause on disbursement of funds appropriated by the Inflation Reduction Act (“IRA”) and Infrastructure Investment and Jobs Act (“IIJA”).
  • EO 14151, “Ending Radical and Wasteful Government DEI Programs and Preferencing,” which directed agencies to take steps to terminate “environmental justice” and “diversity, equity, inclusion, and accessibility” (“DEIA”) mandates, policies, programs, preferences, and activities in the federal government, including “equity-related” grants or contracts, and all “DEI or DEIA performance requirements for employees, contractors, or grantees.”
  • EO 14169, “Reevaluating and Realigning U.S. Foreign Aid,” which, among other things, directed agencies to “immediately pause new obligations and disbursements of development assistance funds…”
  • Further information on these and other EOs can be found on Covington’s Inside Government Contracts blog.
• January 27: The Office of Management and Budget (“OMB”) issued Memorandum M-25-13 pausing federal assistance funds.
• January 28:
  • Two cases were filed challenging M-25-13: National Council of Nonprofits v. Office of Management and Budget, No. 1:25-cv-00239 (D.D.C.), and State of New York v. Trump, No. 1:25-cv-00039 (D.R.I.).OMB issued instructions listing programs for which OMB is seeking more information during the review period. The White House also issued a Q&A that noted M-25-13 “does not apply across-the-board.” The Department of Defense (“DoD”) clarified that M-25-13 does not affect contracts.
  • In National Council of Nonprofits v. Office of Management and Budget, D.D.C. issued an administrative stay pausing enforcement of M-25-13 through February 3.
• January 29:
  • OMB rescinded M-25-13.
  • Following the recission of M-25-13, the White House Press Secretary indicated that EOs “on federal funding remain in full force and effect.”
• January 31:
  • In State of New York v. Trump, D.R.I. issued a temporary restraining order (“TRO”) against M-25-13, despite OMB’s recission of M-25-13. The TRO stated, in part, that defendants in the case were “restrained and prohibited from reissuing, adopting, implementing, or otherwise giving effect to the OMB Directive under any other name or title or through any other Defendants (or agency supervised, administered, or controlled by any Defendant), such as the continued implementation identified by the White House Press Secretary’s statement of January 29, 2025.”
  • The Department of Justice (“DOJ”) issued notices to agencies to implement the TRO.
• February 3:
  • In National Council of Nonprofits v. Office of Management and Budget, D.D.C. issued a TRO under which the government was “enjoined from implementing, giving effect to, or reinstating under a different name the directives in OMB Memorandum M-25-13 with respect to the disbursement of Federal funds under all open awards.”
  • OMB issued a memorandum to agencies directing compliance with the TRO, but noting that these instructions “do not restrict agencies’ compliance with the President’s recently issued EOs, nor do they restrict agencies’ ability to take actions pursuant to their own authorities independent of OMB Memorandum M-25-13.”
• February 7:
  • Plaintiffs in State of New York v. Trump filed a motion to enforce the TRO, arguing that defendants had not fully complied and specifically challenging defendants’ argument that IRA and IIJA funding was outside the scope of the TRO.
  • The National Institutes of Health (“NIH”) issued guidance imposing a standard indirect cost rate on all NIH grants of 15%.
• February 10:
  • In State of New York v. Trump, plaintiffs’ motion to enforce the TRO pertaining to M-25-13 was granted. DOJ appealed to the U.S. Court of Appeals for the First Circuit (“First Circuit”).
  • Three complaints were filed challenging the NIH guidance regarding indirect rates:  Massachusetts v. National Institutes of Health, No. 1:25-cv-10338 (D. Mass); Association of American Medical Colleges v. National Institutes of Health, No. 1:25-cv-10340 (D. Mass); and Association of American Universities v. Department of Health & Human Services, No. 1:25-cv-10346 (D. Mass).  
  • In Massachusetts v. National Institutes of Health, the court granted an emergency TRO with respect to plaintiff states, and in Association of American Medical Colleges v. National Institutes of Health, the court granted a separate TRO with respect to “institutions” nationwide.
• February 11: In State of New York v. Trump, the First Circuit denied defendants’ request for an administrative stay of the district court’s TRO pertaining to M-25-13.
• February 12: In State of New York v. Trump, the district court denied defendants’ emergency motion for relief or clarification of the TRO pertaining to M-25-13, but noted that the TRO permits limiting access to funds on the basis of applicable statutes, regulations, and terms without preclearance from the court.  The district court also denied defendants’ motion for a stay pending appeal.
• February 13:
  • Complaint was filed in Shapiro v. U.S. Department of the Interior, No. 2:25-cv-00763 (E.D. Pa.), challenging the funding freeze as it relates to Pennsylvania. Plaintiffs in State of New York v. Trump filed an amended complaint, replacing their challenge to the “OMB Memo” with a blanket challenge to the “Federal Funding Freeze.”
  • The First Circuit appeal of the TRO in State of New York v. Trump was voluntarily dismissed.
• February 18: 
  • The White House issued “Radical Transparency about Wasteful Spending” memorandum directing agencies to make transparent “the complete details of every terminated program, cancelled contract, terminated grant, or any other discontinued obligation of Federal funds.”
  • Under Secretary of Defense for Acquisition and Sustainment issued memorandum directing “Review and Validation of Contracts for Consulting Services.”
• February 25:  D.D.C. granted plaintiffs’ motion for a preliminary injunction against M-25-13 in National Council of Nonprofits v. Office of Management and Budget.
• February 28:  Plaintiffs in State of New York v. Trump filed second motion to enforce the D.R.I. TRO pertaining to M-25-13, specifically with respect to Federal Emergency Management Agency grants.
• March 4:  Plaintiffs in National Council of Nonprofits v. Office of Management and Budget asked D.D.C. to clarify that its preliminary injunction against M-25-13 “applies to federal grants that have been awarded.”
• March 5: 
  • D. Mass. granted a preliminary injunction in Massachusetts v. National Institutes of Health, Association of American Medical Colleges v. National Institutes of Health, and Association of American Universities v. Department of Health & Human Services, prohibiting the implementation, application, or enforcement of the NIH guidance regarding indirect rates with respect to “institutions nationwide.”
  • Complaint was filed in National Endowment for Democracy v. United States, No. 1:25-cv-00648 (D.D.C.), challenging withholding of congressionally appropriated funds.
• March 6:  In State of New York v. Trump, D.R.I. granted a preliminary injunction against the federal funding freeze.
• March 10:  Defendants in State of New York v. Trump appealed D.R.I.’s preliminary injunction against the federal funding freeze to the First Circuit.

2.     DEI and Gender

• January 20: In addition to the “Ending Radical and Wasteful Government DEI Programs” EO mentioned above, President Trump signed various EOs concerning DEIA and gender. These include:
  • EO 14168, “Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government,” which defined sex as an “immutable biological characteristic” and required the federal government to recognize binary biological sex and cease promoting gender ideology.
  • EO 14170, “Reforming the Federal Hiring Process and Restoring Merit to Government Service,” which required DOGE to create a Federal Hiring Plan preventing hiring based on “race, sex, or religion.”
  • EO 14148, “Initial Rescissions of Harmful Executive Orders and Actions,” which, among other things, rescinded EO 14035, “Diversity, Equity, Inclusion, and Accessibility in the Federal Workforce.”
• January 21:
  • President Trump issued EO 14173, “Ending Illegal Discrimination and Restoring Merit-Based Opportunity,” which revoked EO 11246, a 59-year old EO that required federal contractors to promote equal opportunity, and created a certification requirement for contractors to confirm compliance with anti-discrimination laws. The Office of Personnel Management (“OPM”) issued a memorandum, which required agency heads to send notice to employees, take down outward facing media, submit a list of DEIA offices and contracts to OPM, and submit a list of all contract descriptions or personnel position descriptions that had changed since November 5, 2024 to obscure their connection to DEIA.
• January 24:
  • OPM issued a memorandum regarding reduction in force (“RIF”), directing agencies to begin issuing RIF notices to employees of DEIA and “environmental justice” offices.
  • The Secretary of Labor issued an order to cease all investigative and enforcement activity under rescinded EO 11246, and to hold in abeyance Section 503 (pertaining to discrimination against individuals with disabilities) and Vietnam Era Veterans’ Readjustment Assistance Act (“VEVRAA”) components of investigation or review.
• January 28: The Under Secretary of Defense issued a memorandum implementing EO 14151 and the corresponding OPM memorandum, instructing DoD contracting officers to immediately terminate solicitations and contracts or contract-like instruments relating to DEIA. The memorandum also applies to contracts executed by a federal partner via assisted acquisition, and requires submission to the Office of the Under Secretary of Defense identifying details of DEIA-related contracts.
• January 29:
  • OPM sent guidance instructing federal agencies to review and eliminate programs, materials, and policies that promote gender ideology in accordance with EO 14168.
  • Secretary of Transportation Duffy issued a memorandum implementing DEI and environmental EOs.
• January 30: Secretary of Defense Pete Hegseth established an anti-DEI task force.
• January 31:
  • The Secretary of Defense issued a memorandum to the DoD Components and Defense Agencies instructing them to “remove all traces of gender ideology” pursuant to EO 14168.
• February 3:  National Association of Diversity Officers in Higher Education v. Trump, No.1:25-cv-00333 (D. Md.) was filed, challenging EOs 14151 and 14173.
• February 4:
  • Doctors for America v. OPM, No. 1:25-cv-00322 (D.D.C.) was filed, challenging the removal of health-related data from agency websites, brought by doctors and scientists who rely on the removed data.
  • The Department of the Air Force issued a memorandum implementing EO 14168 in response to the January 31 memorandum from the Secretary of Defense.
  • The Department of Education issued a “Dear Colleague” letter describing the Department’s actions to revert enforcement of Title IX to pre-Biden administration interpretations of “on the basis of sex.”
• February 5:
  • OPM issued a memorandum that reemphasized and clarified the scope of EOs 14151, 14173, and 14148. The memorandum provided guidance regarding agency actions, such as with respect to affinity groups within agencies.
  • Newly sworn-in Attorney General Pam Bondi issued a memorandum to DOJ implementing EO 14173 and directing the Civil Rights Division and Office of Legal Policy to issue a report by March 1 identifying, among other things, “specific steps or measures to deter the use of DEI and DEIA programs or principles that constitute illegal discrimination or preferences, including proposals for criminal investigations and for up to nine potential civil compliance investigations.”
• February 6: Senators Rick Scott and Eric Schmitt joined Congressmember Michael Cloud in introducing the Dismantle DEI Act, which would codify President Trump’s executive actions regarding DEIA.
• February 7:
  • Orr v. Trump, No. 1:25-cv-10313 (D. Mass.) was filed, challenging the Defending Women EO 14168 as applied to passports.
  • The Secretary of Defense issued a memorandum halting the recruitment of transgender individuals as well as gender-affirming medical care for current service members.
• February 11:  The court in Doctors for America v. OPM issued a TRO ordering restoration of health-related websites and datasets which had previously been removed and modified.
• February 14: The Department of Education issued a second “Dear Colleague” letter interpreting the Supreme Court’s decision in Students for Fair Admissions, Inc. v. President & Fellows of Harvard Coll., 600 U.S. 181 (2023) to apply more broadly than just university admissions.
• February 15: The Civilian Agency Acquisition Council (“CAAC”) issued CAAC Letter 2025-01 authorizing agencies to issue class deviations to ensure compliance with EOs 14173 and 14168.
• February 17: Doe 1 v. Office of the Director of National Intelligence, No. 1:25-cv-00300 (E.D. Va.), was filed, challenging termination of government personnel performing DEIA-related functions under EO 14151.
• February 18:
  • A General Services Administration (“GSA”) press release announced FAR Class Deviations and guidance for contracting officers relating to EO 14173 and EO 14148.
  • CAAC issued Supplement 1 to CAAC Letter 2025-01 announcing additional FAR Class Deviations relating to EO 14173 and EO 14168 to remove references to the Apprentices and Trainees clause removed in the original letter.
  • The court in Doe 1 v. Office of the Director of National Intelligence issued administrative stay blocking termination of plaintiffs in suit challenging termination of government personnel performing DEIA-related functions.
• February 19:  Amended complaint filed in State of Washington v. Trump, No. 2:25-cv-00244 (W.D. Wa.), challenging, among others, EO 14168.
• February 21:  The court in National Association of Diversity Officers in Higher Education v. Trump granted, in part, plaintiffs’ motion for preliminary injunction against certain provisions of EOs 14151 and 14173.
• February 24:  Defendants in National Association of Diversity Officers in Higher Education v. Trump appealed the preliminary injunction against certain provisions of EOs 14151 and 14173 to the U.S. Court of Appeals for the Fourth Circuit.
• February 27:  Plaintiffs in National Association of Diversity Officers in Higher Education v. Trump filed motion to clarify the scope of the preliminary injunction against enforcement of certain provisions of EOs 14151 and 14173.
• February 28: 
  • Department of Education issued Frequently Asked Questions About Racial Preferences and Stereotypes Under Title VI of the Civil Rights Act.
  • In State of Washington v. Trump, court granted partial preliminary injunction blocking enforcement of certain provisions of EO 14168.
• March 3:  The court in National Association of Diversity Officers in Higher Education v. Trump denied defendants’ motion to stay the preliminary injunction enjoining certain provisions of EOs 14151 and 14173 pending appeal.
• March 4:  DoD’s Defense Pricing, Contracting, and Acquisition Policy Office issued Class Deviation 2025-O0003 implementing EOs 14173 and 14168.
• March 5:  Complaint was filed in National Education Association v. U.S. Department of Education, No. 1:25-cv-00091 (D.N.H.), challenging Department of Education “Dear Colleague” Letter.
• March 10: 
  • Complaint was filed in San Francisco Unified School District v. AmeriCorps, No. 3:25-cv-02425 (N.D. Cal.), challenging AmeriCorps directive requiring grant recipients to certify compliance with DEI-related EOs or lose their grant funding.
  • The court in National Association of Diversity Officers in Higher Education v. Trump clarified the scope of the preliminary injunction to include all other federal executive branch agencies, departments, and commissions, and their heads, officers, agents, and subdivisions.

3.     Energy and Environment

• January 20: In addition to the “Unleashing American Energy” EO, President Trump signed several other EOs relating to environmental and energy policy, including the “Declaring a National Energy Emergency” EO, “Unleashing Alaska’s Extraordinary Resource Potential” EO, “Temporary Withdrawal of All Areas on the Outer Continental Shelf from Offshore Wind Leasing and Review of the Federal Government’s Leasing and Permitting Practices for Wind Projects” memorandum, and “Putting America First in International Environmental Agreements” EO. These EOs directed various actions, including:
  • Directing agencies to withdraw areas for wind energy leasing, and ordering agencies to not issue approvals for onshore or offshore wind projects.Disbanding the Interagency Working Group on the Social Cost of Carbon and requiring EPA to issue guidance within 60 days addressing the effect of this action and consider eliminating the Social Cost of Carbon altogether.Ordering the Council on Environmental Quality (“CEQ”) to issue new guidance on implementing the National Environmental Policy Act (“NEPA”) and propose rescinding the current NEPA regulations, and revoking the EO that authorizes CEQ to issue binding regulations under NEPA.Directing agencies to use emergency authorities to facilitate permitting, including under the Endangered Species Act.
  • Ordering a series of actions to initiate oil and gas exploration, leasing, and extraction in the Arctic National Wildlife Refuge.
• February 3: Secretary of Interior Doug Burgum signed six Secretary’s Orders to “Unleash American Energy.”
• February 5:
  • The House Subcommittee on Energy held a hearing on the “Unleashing American Energy” EO.
  • Attorney General Bondi issued a memorandum entitled “Rescinding ‘Environmental Justice’ Memoranda,” which rescinds Biden-era memoranda that sought to implement “‘environmental justice’ agenda.”
• February 6: The Federal Highway Administration issued a memorandum rescinding the National Electric Vehicle Infrastructure (“NEVI”) Formula Program Guidance, and suspending approval of State Electric Vehicle Infrastructure Deployment Plans.
• February 10: President Trump signed EO 14208, “Ending Procurement and Forced Use of Paper Straws.”
• February 14: EPA Administrator Lee Zeldin announced that, with assistance of DOGE, EPA had cancelled nine contracts related to DEI, environmental justice, and more.
• February 18: A GSA press release announced FAR Class Deviations and guidance for contracting officers relating to Section 2 of EO 14208.
• February 25: EPA Administrator announced cancellation of 20 additional grants in second round of cuts.
• March 4: EPA Administrator announced cancellation of 21 additional grants in third round of cuts.
• March 10: EPA Administrator announced that, with assistance of DOGE, EPA “cancelled more than 400 additional grants across nine unnecessary programs” as part of “the fourth round of EPA-DOGE partnered cancellations.”
• March 11: EPA eliminated the Office of Environmental Justice and External Civil Rights.

4.     Trade and Foreign Aid

• January 20: In addition to the Reevaluating and Realigning U.S. Foreign Aid EO, President Trump also signed the America First Trade Policy Memorandum, which among other things directed the U.S. Trade Representative, in consultation with the Senior Counselor for Trade & Manufacturing, to review the impact of government procurement commitments in trade agreements (including the World Trade Organization Agreement on Government Procurement (“WTO GPA”)) on the volume of federal government procurement covered by President Trump’s 2017 EO 13788, “Buy American and Hire American,” and issue recommendations to ensure that these agreements “are being implemented in a manner that favors domestic workers and manufacturers, not foreign nations.”
• January 28: Secretary of State Marco Rubio issued an Emergency Humanitarian Waiver to Foreign Assistance Pause.
• January 29: The Department of State issued guidance on the foreign aid pause and applications for waivers.
• February 1: President Trump ordered tariffs on Canada and Mexico and increased tariffs on China.
• February 3:
  • President Trump agreed to a 30-day pause on tariffs with Canada and Mexico.
  • The White House released guidance on “waste and abuse” at USAID.
  • President Trump ordered the creation of U.S. sovereign wealth fund.
• February 4:
  • A statement on the USAID website announced that all USAID personnel were placed on administrative leave and recalled by February 7.
  • The United States Postal Service (“USPS”) temporarily suspended acceptance of international parcels from China and Hong Kong.
• February 5: USPS resumed acceptance and delivery of packages from China and Hong Kong.
• February 7: Following filing of American Foreign Service Association v. Trump, No. 1:25-cv-00352 (D.D.C.) by organizations representing federal and foreign service employees, D.D.C. issued a TRO blocking USAID from placing employees on administrative leave.
• February 10:
  • President Trump issued EO 14209, “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security.”
  • AIDS Vaccine Advocacy Coalition v. United States Department of State, No. 1:25-cv-00400 (D.D.C.) was filed challenging the pause on foreign aid.

• February 11:  Global Health Council v. Trump, No. 1:25-cv-00402 (D.D.C.), was filed in D.D.C. challenging the pause on foreign aid.
• February 13:
  • President Trump issued a memorandum introducing a reciprocal tariff plan.
  • In AIDS Vaccine Advocacy Coalition v. United States Department of State and Global Health Council v. Trump, D.D.C. granted, in part, a TRO blocking a blanket suspension of foreign aid funding for awards that were in existence as of January 19, 2025.
• February 18: 
  • Complaint was filed in Personal Services Contractor Association v. Trump, No. 1:25-cv-00459 (D.D.C.), challenging suspension of foreign aid assistance and dismantling of USAID.
  • Complaint was filed in United States Conference of Catholic Bishops v. U.S. Department of State, No. 1:25-cv-00465 (D.D.C.), challenging the suspension of foreign aid assistance and of refugee resettlement funding and seeking reimbursement of funds under cooperative agreements.
• February 20:
  • The court in AIDS Vaccine Advocacy Coalition v. United States Department of State and Global Health Council v. Trump granted, in part, plaintiffs’ motions to enforce the TRO blocking suspension of foreign aid funding “to the extent Defendants have not complied with the terms of the TRO.”
  • The Office of the U.S. Trade Representative announced a request for comments to assist in “reviewing and identifying any unfair trade practices by other countries, and in initiating all necessary actions to investigate the harm to the United States from any non-reciprocal trade arrangement.”
  • The court in United States Conference of Catholic Bishops v. U.S. Department of State denied plaintiffs’ motion for a TRO.
• February 25:  Defendants in AIDS Vaccine Advocacy Coalition v. United States Department of State and Global Health Council v. Trump appealed D.D.C.’s oral grant of plaintiff’s motion to enforce the TRO enjoining the pause on foreign aid to the U.S. Court of Appeals for the D.C. Circuit.  Defendants moved to stay the order pending appeal.
• February 26:
  • The court in AIDS Vaccine Advocacy Coalition v. United States Department of State and Global Health Council v. Trump denied defendants’ motion to stay the order enforcing the TRO pending appeal.
  • In response to the denial, defendants’ filed an application to vacate the district court’s order enforcing the TRO enjoining the pause on foreign aid.  The Supreme Court granted a stay of the enforcement order pending further order of the Supreme Court.
• March 2:  Senior USAID official was placed on administrative leave after two internal memoranda shared by the official were filed in Global Health Council v. Trump detailing the impact of recent events on USAID.
• March 3: 
  • President Trump proceeded with imposing tariffs on imports from Canada and Mexico.
  • Plaintiffs in United States Conference of Catholic Bishops v. U.S. Department of State filed an amended complaint challenging the termination of their refugee resettlement cooperative agreements, as well as an amended motion for preliminary injunction.
• March 5:  In AIDS Vaccine Advocacy Coalition v. United States Department of State and Global Health Council v. Trump, the Supreme Court denied defendants’ application to vacate the district court’s order enforcing the TRO enjoining the pause on foreign aid.
• March 6: 
  • In Personal Services Contractor Association v. Trump, D.D.C. issued an oral ruling denying plaintiffs’ request for a TRO and finding that the case was likely a contractual dispute that could not be heard in a federal district court.
  • President Trump granted a one-month pause to tariffs on USMCA-compliant goods from Mexico and Canada.
• March 10:  In AIDS Vaccine Advocacy Coalition v. United States Department of State and Global Health Council v. Trump, D.D.C. partially granted plaintiffs’ motion for a preliminary injunction enjoining portions of EO 14169.
• March 11: In United States Conference of Catholic Bishops v. U.S. Department of State, D.D.C. denied plaintiffs’ amended motion for preliminary injunction on jurisdictional grounds.
• March 12: President Trump implemented 25% tariffs on all imports of steel and aluminum.

5.     DOGE and Federal Workforce

• January 20: President Trump issued several executive actions related to governmental efficiency and federal hiring, including:

• EO 14158, “Establishing and Implementing the President’s “Department of Government Efficiency,” which “establishes the Department of Government Efficiency to implement the President’s DOGE Agenda, by modernizing Federal technology and software to maximize governmental efficiency and productivity.”
  • The “Hiring Freeze” memorandum directed the Director of OMB, in consultation with the Director of OPM, and the U.S. DOGE Service (“USDS”) Administrator, to submit a plan “to reduce the size of the Federal Government’s workforce through efficiency improvements and attrition.”
  • Others included EO 14170, “Reforming the Federal Hiring Process and Restoring Merit to Government Service,” memorandum 90 FR 8251, “Return to In-Person Work,” and EO 14171, “Restoring Accountability To Policy-Influencing Positions within the Federal Workforce.”
• January 20:
  • Three complaints were filed in D.D.C. challenging the creation of DOGE on the basis that it failed to comply with the Federal Advisory Committee Act: Public Citizen v. Trump, No. 1:25-cv-00164 (D.D.C.); Lentini v. DOGE, No. 1:25-cv-00166 (D.D.C); and American Public Health Association v. Office of Management & Budget, No. 1:25-cv-00167 (D.D.C.).
  • Complaint was filed in National Treasury Employees Union v. Trump, No. 1:25-cv-00170 (D.D.C.), challenging EO 14171, which directed OPM to reclassify civil service members.
• January 28:
  • OPM sent a memorandum to federal employees offering eight months of pay and benefits if they resign by February 6.
  • Complaint was filed in Public Employees for Environmental Responsibility v. Trump, No. 8:25-cv-00260 (D. Md.), challenging EO 14171.
• January 29:  Complaint was filed in American Federation of Government Employees, AFL-CIO v. Trump, No. 1:25-cv-00264 (D.D.C.), challenging OPM guidance reclassifying civil service members.
• February 3:  Complaint was filed in Alliance for Retired Americans v. Bessent, No. 1:25-cv-00313 (D.D.C.), challenging DOGE’s access to Treasury payment systems.
• February 4:
  • Complaint was filed in American Federation of Government Employees, AFL-CIO v. Ezell, No. 1:25-cv-10276 (D. Mass.), challenging the “buyout” offer as arbitrary and capricious under the Administrative Procedure Act.
  • OPM issued a memorandum addressing the legality of the deferred resignation program and stated that the assurances of the program “are binding on the government.”
  • The Central Intelligence Agency (“CIA”) reportedly sent a “buyout” offer to its entire workforce.
• February 5:
  • The House Committee on Oversight and Reform held a full-committee hearing on “Rightsizing Government.”
  • Complaint was filed in American Federation of Labor and Congress of Industrial Organizations v. Department of Labor, No. 1:25-cv-00339 (D.D.C.), challenging DOGE’s access to Department of Labor (“DOL”) data and systems.
• February 6:
  • The White House Press Secretary announced the federal government would cancel $8 million in Politico subscriptions.In Alliance for Retired Americans v. Bessent, D.D.C. entered an order adopting the parties’ joint stipulation that access to Treasury records would be limited to two special government employees.In American Federation of Government Employees, AFL-CIO v. Ezell, D. Mass. extended the federal workforce buyout deadline from Thursday, February 6 to Monday, February 10, to allow the court time to assess the legality of the plan.
  • Complaint was filed in Government Accountability Project v. United States Office of Personnel Management, No. 1:25-cv-00347 (D.D.C.), challenging OPM’s guidance reclassifying members of the civil service.
• February 7:
  • Complaint was filed in State of New York v. Donald J. Trump, No. 1:25-cv-01144 (S.D.N.Y.), challenging DOGE’s access to Treasury payment systems.
  • Complaint was filed in University of California Student Association v. Carter, No. 1:25-cv-00354 (D.D.C.), challenging DOGE’s access to Department of Education systems.
  • In American Federation of Labor and Congress of Industrial Organizations v. Department of Labor, D.D.C. denied a motion for a TRO enjoining DOGE’s access to DOL records, for lack of standing.
• February 8:
  • In State of New York v. Donald J. Trump, S.D.N.Y. issued an emergency TRO blocking DOGE’s access to Treasury payment systems.
  • DOGE gained access to CFPB records.
• February 9: DOJ filed an emergency motion to vacate the TRO in State of New York v. Donald J. Trump, regarding DOGE’s access to Treasury systems.
• February 10:
  • Additional complaints were filed in American Federation of Teachers v. Bessent, No. 8:25-cv-00430 (D. Md.) and Electronic Privacy Information Center v. U.S. Office of Personnel Management, No. 1:25-cv-00255 (E.D. Va.), challenging DOGE’s access to government records.
  • The federal workforce buyout deadline was further delayed pending completion of briefing and oral argument while D. Mass. case proceeded.
• February 11:
  • In State of New York v. Donald J. Trump, S.D.N.Y. ruled on DOJ’s emergency motion to vacate the February 8 TRO regarding DOGE’s access to Treasury systems, clarifying the TRO did not extend to access by the Treasury Department’s senior leadership but that it did extend to “political appointees” more broadly.
  • President Trump signed EO 14210, “Implementing the President’s “Department of Government Efficiency” Workforce Optimization Initiative.” The EO mandated that the DOGE Hiring Plan require that each agency hire no more than one employee for every four employees that depart.
• February 12: In American Federation of Government Employees, AFL-CIO v. Ezell, D. Mass. dissolved the TRO preventing implementation of the federal workforce buyout, finding that the plaintiffs lacked standing.
• February 13: Fourteen states filed a lawsuit, State of New Mexico v. Musk, No. 1:25-cv-00429 (D.D.C.), challenging DOGE’s authority under the Appointments Clause.
• February 17: In University of California Student Association v. Carter, D.D.C. denied plaintiffs’ motion for a TRO in case challenging DOGE’s access to Department of Education records due to lack of irreparable harm.
• February 18:
  • The White House issued a memorandum for agency heads directing agencies to make details public about programs, contracts, and grants terminated. President Trump issued EO 14215, “Ensuring Accountability for All Agencies,” which requires all executive departments and agencies, “including so-called independent agencies,” to “submit for review all proposed and final significant regulatory actions to the Office of Information and Regulatory Affairs” before Federal Register publication, and directs the chairs of independent regulatory agencies to “regularly consult with and coordinate policies and priorities with the directors of OMB, the White House Domestic Policy Council, and the White House National Economic Council.”  Additionally, the order provides that “[t]he President and the Attorney General, subject to the President’s supervision and control, shall provide authoritative interpretations of law for the executive branch.”
  • In State of New Mexico v. Musk, D.D.C. denied plaintiffs’ request for a TRO in case by states challenging DOGE’s lawful authority under the Appointments Clause.
• February 20:  Plaintiffs filed a Freedom of Information Act (“FOIA”) challenge seeking information from DOGE records in Citizens for Responsibility and Ethics in Washington v. U.S. DOGE Service, No. 1:25-cv-00511 (D.D.C.).
• February 21:
  • In Electronic Privacy Information Center v. U.S. Office of Personnel Management, challenging DOGE’s access to Treasury and OPM records, court converted plaintiffs’ motion for a TRO to a preliminary injunction and denied the motion on the basis that the plaintiffs had not established irreparable harm.
  • In State of New York v. Donald J. Trump, challenging DOGE’s access to Treasury records, court granted a preliminary injunction enjoining Treasury from allowing DOGE employees or contractors access to Treasury systems.
• February 24: In American Federation of Teachers v. Bessent, court partially granted plaintiffs’ motion for a TRO in case challenging DOGE access to Treasury, Department of Education, and OPM records containing personal information.
• February 26:
  • President Trump issued EO 14222, “Implementing the President’s ‘Department of Government Efficiency’ Cost Efficiency Initiative,” which established new requirements relating to both new and existing “covered contracts and grants,” including, among other things, requiring agencies to create new payment tracking systems and to review all current covered contracts and grants within 30 days to ensure alignment with the Administration’s policy.  A Covington client alert detailing the requirements of the EO is available here.
  • OMB and OPM issued memorandum to agency heads communicating guidance on agency reductions in force and reorganization plans requested by EO 14210.
• March 3: 
  • Defendants in State of New York v. Donald J. Trump filed a letter requesting the court to confirm whether the scope of the preliminary injunction prevents defendants from accessing the IRS Procurement for Public Sector system.
  • Complaint was filed in Center for Biological Diversity v. U.S. Department of Interior, No. 1:25-cv-00612 (D.D.C.), challenging DOGE as violation of APA and FACA.
• March 4:  Plaintiffs in State of New York v. Donald J. Trump filed a letter opposing defendants’ request that the court confirm whether the scope of the preliminary injunction prevents defendants from accessing the IRS Procurement for Public Sector system.
• March 5:  Complaint was filed in Japanese American Citizens League v. Musk, No. 1:25-cv-00643 (D.D.C.), challenging various DOGE actions.
• March 6:  Complaint was filed in Maryland v. U.S. Department of Agriculture, No. 1:25-cv-00748 (D. Md.), challenging RIFs as violation of APA in failing to follow necessary procedures.
• March 7: 
  • In State of New York v. Donald J. Trump, S.D.N.Y. responded to defendants’ letter by modifying the preliminary injunction to exclude the PPS software application from restrictions on access.
  • In Alliance for Retired Americans v. Bessent, D.D.C. denied plaintiffs’ motion for a preliminary injunction preventing DOGE’s access to Treasury systems.
• March 10:  In Citizens for Responsibility and Ethics in Washington v. U.S. DOGE Service, D.D.C. granted in part plaintiffs’ motion for a preliminary injunction finding that the U.S. DOGE Service was likely subject to FOIA.