DC Circuit Rejects US Bid to Remove Voice of America Director

The US Agency for Global Media is barred from removing Voice of America Director Michael Abramowitz while it appeals a court order that held his ouster was illegal.

Although the US Supreme Court earlier this year blocked orders to reinstate fired officers because of the risk of harm to the government, “this is not a like case,” the US Court of Appeals for the DC Circuit said in a per curiam order Monday.

When an injunction against the removal of an officer neither permits them to exercise executive power, nor threatens to “disrupt the proper functioning of the Executive Branch,” the government doesn’t face the risk of harm the Supreme Court identified in those earlier cases, Trump v. Boyle and Trump v. Wilcox, the DC Circuit said.

Abramowitz and other VOA journalists sued USAGM and agency officials in two separate lawsuits in March after President Donald Trump directed the agency be reduced to its minimum functions required by law. While litigation was ongoing, Abramowitz was notified that he was being removed from his role. A DC district judge granted Abramowitz partial summary judgment, concluding his removal was “plainly contrary to law.”

The Supreme Court earlier this year held that the government faced a greater risk of harm from an order reinstating fired National Labor Relations Board member Gwynne Wilcox and Consumer Product Safety Commission member Mary Boyle and others than the harm those officers faced.

But the VOA director is an inferior officer, “and neither the President nor the CEO” of USAGM can remove or appoint anyone to that role without majority approval from the International Broadcasting Advisory Board, which “has been inquorate since January.” So the president wouldn’t be able to replace Abramowitz until he nominates, and the Senate confirms, new board members, the DC Circuit said.

Abramowitz is also still on administrative leave under a separate action not at issue in the appeal, the court added, so he’s not exercising any executive power.

Judges Patricia A. Millett, Cornelia T.L. Pillard, and Bradley N. Garcia joined the unsigned order.

Zuckerman Spaeder LLP represents Abramowitz.

The case is Abramowitz v. Lake, D.C. Cir., No. 25-05314, 10/6/25.