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Blue-State Grantees Vindicated by Federal Court

By Aron C. Beezley, Nathaniel J. Greeson & Gabrielle A. Sprio on January 13, 2026
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Blue-State Grantees Vindicated by Federal Court

Table of Contents

  • Background: Political Classification in Grant Terminations
  • Legal Claims
  • Court’s Findings
  • 1. Equal Protection (Fifth Amendment)
  • 2. First Amendment
  • 3. Remedies
  • Significance and Takeaways
  • Conclusion

The U.S. District Court for the District of Columbia recently issued a significant ruling in City of Saint Paul, Minnesota, et al. v. Christopher Wright, addressing constitutional constraints on executive agency conduct in the context of federal grant terminations. The decision — issued by Judge Amit P. Mehta — saw the court enter judgment for the plaintiffs on their Fifth Amendment equal protection claim while rejecting a related First Amendment theory.

Link to Background: Political Classification in Grant Terminations Background: Political Classification in Grant Terminations

The plaintiffs in the case are environmental project grantees and sub-grantees (including the City of Saint Paul, Plug In America, Interstate Renewable Energy Council, Elevate Energy, Southeast Community Organization, and Environmental Defense Fund) whose projects were funded through Department of Energy (DOE) grants. These grantees are based in states that generally voted for Democratic candidates in the 2024 presidential election.

In October 2025, just as a government shutdown began, the DOE — under Secretary Christopher Wright — terminated hundreds of awards totaling billions of dollars in funding. DOE issued press releases and termination notices claiming the projects did not further agency priorities, but plaintiffs alleged that the terminations were not genuinely grounded in programmatic considerations. Instead, they argued the decisions were driven by the political identity of the grantees’ states, effectively targeting those from “Blue states” and sparing similar awards in “Red states.”

Link to Legal Claims Legal Claims

Plaintiffs asserted two central constitutional claims. First, they claimed that defendants’ categorization of grantees based on the political character of their states — terminating awards in states that did not support President Trump in 2024 — denied them equal protection under the law. Second, plaintiffs further argued that the terminations constituted viewpoint discrimination and retaliation based on political beliefs and association.

Link to Court’s Findings Court’s Findings

Link to 1. Equal Protection (Fifth Amendment) 1. Equal Protection (Fifth Amendment)

    Judge Mehta ruled decisively in favor of the plaintiffs. The court found that there was an unequivocal classification between grantees in “Blue states” and those in “Red states.” Although defendants offered a “legitimate interest” — aligning grants with current agency priorities — the court concluded that terminating grants primarily because awardees were located in states that opposed President Trump’s 2024 candidacy was not rationally related to that purpose. Critically, plaintiffs demonstrated that their terminated awards were comparable to other DOE grants in Republican-leaning states that were not terminated, undermining any rational basis for the disparate treatment. Thus, the court held that defendants’ actions violated the equal protection component of the Fifth Amendment.

    Link to 2. First Amendment 2. First Amendment

    The court rejected plaintiffs’ First Amendment claim on standing grounds. Plaintiffs sought to assert the rights of an undifferentiated mass of citizens of Blue states, claiming those citizens were subject to discrimination or retaliation because of a political viewpoint. The court held plaintiffs lacked standing to assert such broad third-party rights, noting there was no clear identity of interests between the plaintiffs’ interests in restoring their grants and the diverse political views of millions of third-party voters.

    Link to 3. Remedies 3. Remedies

    Given the constitutional violation under the Fifth Amendment, the court declared defendants’ challenged terminations unlawful; vacated the October 2025 termination notices for the seven awards at issue; and directed the parties to file a joint status report to address prospective injunctive relief and attorneys’ fees.

    Link to Significance and Takeaways Significance and Takeaways

    This decision is noteworthy for several reasons. First, the ruling underscores that federal agencies cannot use discretionary funding decisions as a vehicle for political retaliation or reward when such decisions lack a rational relation to legitimate governmental interests.

    Second, the court reaffirmed that classifications based on political alignment or geography still must withstand rational basis scrutiny and cannot be arbitrary or baseless.

    Third, the court’s dismissal of the First Amendment claim highlights the challenges of asserting broad third-party rights without a clear alignment of interests.

    As litigation continues — particularly regarding injunctive relief and costs — this opinion will likely serve as an important precedent for future constitutional challenges to politically motivated administrative actions.

    Link to Conclusion Conclusion

    Bradley has significant experience representing federal grantees in a variety of matters. If your federal grant has been terminated, please feel free to reach out to Aron Beezley, Nathaniel Greeson, or Gabby Sprio to discuss whether relief may be available.

    Photo of Aron C. Beezley Aron C. Beezley

    Aron Beezley is the co-leader of Bradley’s nationally ranked Government Contracts Practice Group. Ranked nationally himself in Government Contracts Law by Chambers, Law360, Benchmark Litigation, and Super Lawyers, Aron’s vast experience includes representation of government contractors in numerous industries…

    Aron Beezley is the co-leader of Bradley’s nationally ranked Government Contracts Practice Group. Ranked nationally himself in Government Contracts Law by Chambers, Law360, Benchmark Litigation, and Super Lawyers, Aron’s vast experience includes representation of government contractors in numerous industries and in all aspects of the government-contracting process, including negotiation, award, performance and termination.

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    Photo of Nathaniel J. Greeson Nathaniel J. Greeson

    Nathaniel Greeson helps clients solve government contracts challenges. Nathaniel represents clients in a range of government procurement issues, including bid protests, claims, disputes, audits and investigations. He has extensive experience with GAO bid protests, agency-level protests, Court of Federal Claims (COFC) bid protests…

    Nathaniel Greeson helps clients solve government contracts challenges. Nathaniel represents clients in a range of government procurement issues, including bid protests, claims, disputes, audits and investigations. He has extensive experience with GAO bid protests, agency-level protests, Court of Federal Claims (COFC) bid protests, and SBA OHA size and NAICS appeals, as well as experience with agency-level requests for equitable adjustments (REA) and claims, and Boards of Contract Appeals claims. View articles by Nathaniel.

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    Photo of Gabrielle A. Sprio Gabrielle A. Sprio

    Gabby Sprio is an associate in Bradley’s Construction Practice Group. Her practice focuses primarily on government contracts law. Prior to law school, Gabby worked for a leading global aerospace and defense company. In this role, she gained experience in government contract administration and…

    Gabby Sprio is an associate in Bradley’s Construction Practice Group. Her practice focuses primarily on government contracts law. Prior to law school, Gabby worked for a leading global aerospace and defense company. In this role, she gained experience in government contract administration and financial analysis.

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    • Posted in:
      Government and Public Policy
    • Blog:
      BuildSmart
    • Organization:
      Bradley Arant Boult Cummings LLP
    • Article: View Original Source

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