Judge in Job Corps Suit Weighs New High Court Injunction Limits

The US Supreme Court’s landmark decision reining in the use of nationwide injunctions will encounter an early test in a challenge to the US Department of Labor’s decision to end the Job Corps training program.

New York federal judge Andrew L. Carter Jr., will consider the effects of the high court’s Trump v. CASA Inc. decision July 23, after he recently blocked the DOL from shutting down Job Corps centers nationwide. Carter will hear arguments from the government and Job Corps-funded contractors on whether his injunction issued June 25, just days before the justices’ ruling, can stand.

Carter isn’t alone in asking how CASA impacts challenges to Trump’s labor agenda. But, the questions arising in the US District Court for the Southern District of New York suit mark one of the first applications of the new high court ruling in active litigation and could reveal the resulting limits now on lower court judges.

A US District Court for the District of Columbia judge hasn’t yet determined if emergency relief is necessary after a ruling in a separate lawsuit brought by Job Corps students, and similarly requested that the parties explain how CASA affects an injunction.

In both cases Job Corps operators and students who want to preserve the program say that CASA shouldn’t apply, because they’re seeking relief under the Administrative Procedure Act.

CASA “expressly declined to address the ‘distinct question’ whether a Court may set aside unlawful agency action under the Administrative Procedure Act,” attorneys representing the Job Corps contractors in New York wrote.

But it remains an open question as to whether “setting aside” an agency action under the APA should apply nationwide, attorneys say, a key issue in the case that will likely have to be ironed out by the Supreme Court itself.

APA Remedy

Lower courts have traditionally held that the APA’s “set aside” remedy applies universally, said Nicholas Bagley, a University of Michigan administrative law professor.

“But there is reason to doubt that conclusion,” Bagley said, “and there is debate among Supreme Court justices on that very question.”

Justice Neil Gorsuch, appears not to agree that the APA permits courts to block regulations nationwide, according to Daniel Wolff of Crowell & Moring LLP, although he is in the minority.

“Gorsuch would say the same rule that was applied in CASA applies to the APA,” Wolff said.

Ultimately, the high court “is going to have to address the issue of whether ‘set aside’ in the Administrative Procedure Act allows for vacatur, or only allows more literally, set it aside as to the complaining plaintiff,” Wolff added.

The DOL’s attorneys in the New York litigation argue any court action in favor of the Job Corps operators and students that filed the lawsuit should now be limited to the plaintiffs.

Carter’s injunction is “impermissibly overbroad” because it extends to preclude the government from acting with respect to non-parties, the DOL argued in a brief.

The Supreme Court’s omission of the APA in CASA doesn’t apply, the DOL said, because the New York court didn’t set aside the agency’s action under the APA, but granted a preliminary injunction under its “traditional equitable authority.”

That authority “is limited to providing relief to the parties themselves” as CASA made clear, wrote Jay Clayton, the former Securities Exchange Commission chairman, who is interim US attorney for the Southern District.

Program Confusion

Any decision lifting the block on the DOL’s efforts to wind down Job Corps could spur more confusion for participants in the training program for low income young adults, who have received mixed directives as court fights continue.

Many students and staff already left the program as a result of the Trump administration’s efforts.

With the limitation placed on courts following CASA, some Job Corps students that may have returned to the program after the nationwide injunction could see it paused again, if the judges were to grant limited injunctions.

CASA “limits the scope of federal district courts to do nationwide injunctions,” which means you can have multiple individuals file litigation in different states, and you can have inconsistent results based on rulings of the federal judges in those different states,” said Tiffany Releford, a partner at Ice Miller.

The decades-old Job Corps training program provides vocational training, as well as housing, food, and stipends to low-income young adults nationally.

The Trump administration announced at the end of May that it was “pausing operations” at 99 Job Corps centers across the country citing poor performance, budget issues, and serious safety incidents.

But Carter said in blocking the move the administration acted unlawfully in part because it failed to seek notice and comment from the public or notify Congress it would end the program.

The cases are CABRERA v. US DOL, D.D.C., No. 25-01909, and National Job Corps Association v. DOL, S.D.N.Y., No. 25-04641.