Patsy Widakuswara v. Kari Lake & Michael Abramowitz v. Kari Lake

Court of Appeals for the District of Columbia Circuit · May 28, 2025 · No. 25-5144 & 25-5145

Summary

This D.C. Circuit order denies en banc reconsideration of a panel decision that stayed a district court's preliminary injunction against the U.S. Agency for Global Media regarding Voice of America operations. Concurring judicial statements address the scope of the district court's remedial authority under the Administrative Procedure Act and the International Broadcasting Act. The opinions analyze whether the injunction's requirement to restore VOA personnel and programming was properly tailored to remedy arbitrary agency action while maintaining the status quo pending appeal.

Court
Court of Appeals for the District of Columbia Circuit
Writing for the Court
Srinivasan; Pillard; Millett; Wilkins; Childs; Pan; Garcia
Jurisdiction
United States Court of Appeals for the District of Columbia Circuit
Decision date
May 28, 2025
Docket number
25-5144 & 25-5145
Procedural posture
Denial of en banc reconsideration of the panel's emergency stay of the district court's preliminary injunction.
Precedential value
published
Parties
Kari Lake v. Patsy Widakuswara, Michael Abramowitz
Disposition
other

Topics

injunctionsadministrative lawappellate procedurecivil procedureremedies

Practice areas

administrative lawappellate procedurecivil procedureremedies

Questions Presented

  1. Whether the district court had authority to issue a preliminary injunction requiring restoration of VOA employees and contractors.
  2. Whether the panel erred in granting an emergency stay of that preliminary injunction.

Holdings

  1. The en banc court denied reconsideration, leaving the panel's emergency stay in effect.

Key quotations

“the injunction does not prevent USAGM from executing personnel decisions,” or taking other actions regarding employee relations, contract negotiations, or contract terminations, “pursuant to its statutory mandate and in compliance with the APA.” (*5)

Factual background

The government shut down Voice of America (VOA) and terminated personal service contractors, allegedly violating statutory mandates. Plaintiffs alleged the agency acted arbitrarily and capriciously under the APA, prompting the district court to issue a preliminary injunction restoring VOA operations and employees.

Procedural history

The district court entered a preliminary injunction ordering restoration of VOA operations. The panel of this court granted an emergency stay of that injunction. The government sought en banc reconsideration, which was denied.

Court Document

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