Search Executive orders

Education

Bars trans girls from female teams (Title IX rewrite). Non-compliance could result in the withdrawal of federal funds from the offending institutions

The executive order applies to all educational institutions that receive federal funding. Must adopt compliant policies.

Tirrell v. Edelblut, 1:24-cv-00251 (D.N.H.); State of Maine v. USDA, 1:25-cv-00131(Likely to trigger Title IX-based lawsuits especially from transgender student-athletes.)

Education

The order aims to exclude certain organizations from the definition of "public service," thereby affecting the eligibility of their employees for federal student loan forgiveness.

Likely excluded organizations: (1) Provide services to undocumented immigrants or challenge federal immigration; (2) Groups involved in protests or advocacy that result in repeated violations of state laws; (3) Entities that provide or advocate for gender-affirming care, especially for minors, might be targeted; (4) Organizations that engage in activities perceived as promoting illegal discrimination or advocating for radical political change could fall under the exclusion; (5) Faith-based groups whose practices are interpreted as discriminatory or in violation of federal laws may be affected.

As of June 20, 2025, there are no known lawsuits directly challenging Executive Order 14235. Civil rights groups (e.g., NAACP, ACLU) are expected to file lawsuits once agency formal rulemaking actions begin

Education

Threatens derecognition of DEI-minded accreditors.

Specifically, it authorizes actions such as denial, monitoring, suspension, or termination of an accreditor's recognition if they require institutions to adopt DEI initiatives as part of their accreditation process. Pell / loan eligibility impacted.

Accreditor non-delegation suit forming.

Education

Redirects Title I $$ to vouchers / choice.

Public school resources and funding are redirected to private schools. Budget drain for public schools. • Families may have more choices for their children's education, including access to private or specialized schools that were previously unaffordable. But even with vouchers, the cost of private education may remain cost prohibitive for some families (e.g., transportation).

No suits yet; state funding fights loom Q3.

Education

This order directs federal agencies, including the Departments of Education and Health and Human Services, to review and revise guidelines related to the diagnosis and treatment of neurodevelopmental and behavioral conditions in children. The primary focus is to ensure that diagnoses and subsequent treatments, particularly pharmacological interventions, are evidence-based and not influenced by non-medical factors.

For families with neurodivergent children—such as those diagnosed with ADHD, autism spectrum disorder, or mood disorders—this executive order could cause IEP delays; parent-consent hurdles, and delays, added scrutiny of prescriptions for medications like methylphenidate (Ritalin), Adderall, and mood stabilizers.

As of June 27, 2025, there are no active lawsuits challenging Executive Order 14212. This bears watching for those of us with neurodivergent children.

Education

Requires revenue-sharing agreements for revenue-producing college sports to be structured by colleges in such a ways so as to subsidize non-revenue-producing and/or women college sports.

The order affirms NIL agreements, but only if structured in a way that preserves or expands scholarships and athletic opportunities for women and non-revenue sports. In other words, high-revenue athletes may be paid but not at the expense of smaller, less profitable programs. Access to federal monies (e.g., Pell Grants) is the likely enforcement hook.

No litigation as yet

Education

The Order rescinds guidance that used Title VI’s disparate-impact standard to address racial disparities in school discipline.

The Department of Education is directed to issue model policies emphasizing individual misconduct rather than any consideration of a student’s race, disability, or other protected characteristic.

None yet; APA challenge signaled. Though no lawsuits are on file, multiple civil rights groups (e.g., Youth Law Center, Education Civil Rights Alliance, National Center for Learning Disabilities) have publicly condemned the EO warning that it could remove critical protections for students of color and students with disabilities

Education

Starts shuttering DoEd; bans DEI spend.

Closure could disrupt the administration of Pell, IDEA, OCR (office of civil rights).

NAACP v. United States (filed Mar 24 2025, D. Md.) – Civil-rights groups say the Executive Order illegally “dismantles” the Education Department by slashing staff and canceling $1.5 billion in grants, violating the Take-Care Clause, Spending Clause and the APA. A motion for a nationwide preliminary injunction is still pending; none has been issued yet. Somerville Public Schools v. Trump (filed Apr 1 2025, D. Mass.) – School districts and unions argue the President lacks authority to close the Education Department; they sought an emergency halt to mass layoffs. On May 22 2025 the district court granted a preliminary injunction that blocks the shutdown nationwide and orders fired employees reinstated. New York et al. v. McMahon (filed Mar 13 2025, D. Mass.; consolidated with Somerville) – Twenty-one states challenge the same layoffs and transfer of functions as an unconstitutional power-grab and APA violation. The district court’s preliminary injunction (identical nationwide relief) was issued earlier and, on Jun 4 2025, the First Circuit refused to stay it, keeping the nationwide injunction in force.  Carter et al. v. U.S. Dept. of Education (filed Mar 14 2025, D.D.C.) – Parents and disability-rights advocates claim the reduction-in-force deprives students of discrimination investigations, violating due-process and the APA. The court denied their preliminary-injunction motion on May 21 2025 and later stayed the case pending the Somerville/New York appeals; therefore no nationwide injunction is in place. On July 14, 2025, in McMahon v. New York et al., the Supreme Court granted the stay of the injunction that was preventing the closure of the Dept. of Education. This means, the Court effectively lifted the injunction that was holding back EO# 14242, such that the Trump Administration could proceed with dissolving the Dept. of Ed.

Education

Links campus antisemitism enforcement to visa oversight.

Grant loss if deemed lax; OCR investigations. For instance, Columbia University reportedly had $400 million in federal grants revoked due to alleged failures in addressing antisemitism on campus. The Department of Education's Office for Civil Rights has initiated investigations into multiple universities and most recently demanded that the President of Univ. of Virginia stepdown, and who did step down on June 27, 2025. Some of plaintiffs' arguments include that EO 14161 and EO 14188 criminalize or deport international students and scholars based on protected First Amendment activities (e.g., pro-Palestinian protests). Plaintiffs argue visa revocation and deportation procedures based on political viewpoints violate free speech, equal protection, due process, and are vague and overbroad; status is nationwide TRO has been sought to block enforcement of both EOs against plaintiffs..

Harvard v. HHS D. Mass. No. 1:25-cv-11048 (Funding freeze alleged to coerce “viewpoint-diversity” policies at Harvard); Status: Gov’t & Harvard cross-moved for summary judgment (motions filed 6 Jun 2025); argument set 21 Jul 2025. In September 2025, the Court granted a stay of the funding freeze. AAUP – Harvard Faculty Chapter v. DOJ D. Mass. No. 1:25-cv-10910 (EO 14188–based threats of visa revocation targeting faculty speech); Status: Complaint filed 11 Apr 2025; discovery just beginning. AAUP v. DOJ (Columbia) S.D.N.Y. No. 1:25-cv-02429 (Sudden cancellation of ≈ $400 million in Columbia research grants); Status: On 16 Jun 2025 the judge dismissed the case for lack of standing and Plaintiffs plan to appeal. American-Arab ADC et al v. Trump N.D.N.Y. No. 3:25-cv-00335 (EOs 14161 & 14188 allegedly criminalize/deport students for protected speech); Status: Amended complaint & renewed TRO filed 28 Mar 2025; briefing on preliminary injunction ongoing.

Education

Full disclosure of foreign gifts / contracts

Qui-tam & OFAC exposure if SDN (specially-designated nationals) are linked to gifts/contracts.

No current litigation, but increased audit & enforcement risk, including potential qui tam FCA claims or APA challenges.

Education

Establishing the “White House Initiative to Promote Excellence and Innovation at Historically Black Colleges and Universities (HBCUs).” Cancels HBCU collaboration with the EPA but allows HBCU collaboration with the USDA to continue. Encourages more private partnerships.

Possible “Trojan horse” oversight.

Quiet—for now. There’s no litigation as yet. But it bears watching. The EO discontinued HBCU's collaboration with the EPA, but allowed the USDA-HBCU collaboration to continue. The strong support in the EO for HBCUs seems at odds with the Trump Administration's dislike for what it deems to be "DEI" and any critical race theory teaching. Indeed CRT is banned by EO# 13950 (Sept. 22, 2020 – Trump 1.0) in federal workplace training and schools K-12. EO# 14283 seems misaligned with statements coming out of the White House and therefore bears watching.

Education

Reinstates the Presidential Fitness Test nationwide in public schools, reversing the Obama-era policy

Students are now compared and ranked using standardized fitness benchmarks rather than guided by individualized wellness goals. This returns emphasis to physical excellence over universal participation. Proponents say the return promotes physical discipline, national pride, and readiness. Critics argue it may induce stress, shame, and exclusion in students who perform poorly or face physical limitations, potentially undermining the inclusive wellness ethos advanced in 2012

No litigation as yet.

Education

Bans “gender / discriminatory equity ideology”; criminal exposure for teachers who aid social transition w/o parents.

Schools that promote or teach “gender ideology” or “discriminatory equity ideology” risk losing federal funding ; possible misdemeanor/felony charges for "sexual exploitation of a minor" or medical malpractice.

AFT / NEA PIs; NAACP nationwide PI granted (cert. rule). THIS NATIONWIDE PI COULD BE AT RISK DUE TO TRUMP v. CASA. On January 21, 2026, the Trump Administration abandoned its appeal to the 4th Circuit to overturn the District Court's finding that the Dept. of Education's "Dear Colleague Letter" was unenforceable. That means, the District Court's ruling stands. The Dear Colleague Letter is legally unenforceable.

Federal Contractor

This order aims to reinforce First Amendment protections by prohibiting federal agencies from engaging in or facilitating censorship of lawful speech, particularly on digital platforms. The EO claims that the previous administration "trampled free speech rights by censoring Americans' speech on online platforms, often by exerting substantial coercive pressure on third parties, such as social media companies, to moderate, deplatform, or otherwise suppress speech that the Federal Government did not approve."

Executive Order 14149 focuses on preventing federal interference with lawful speech in terms of what people can say on various social platforms

None

Federal Contractor

DOGE gets read-only unclassified data.

Under EO 14158, federal agencies are directed to provide DOGE with full and prompt access to all unclassified agency records, software systems, and IT systems, to the maximum extent consistent with law.

NY + 18 other state AGs are challenging DOGE but not specifically challenging the EO that created DOGE. They claim unauthorized access to payment systems by DOGE. Status: Preliminary injunction in place, blocking DOGE's access. IF THE PI IS NATIONWIDE, IT COULD BE AT RISK DUE TO TRUMP v. CASA. On August 12, 2025, the 4th Circuit overturned (i.e., lifted) the preliminary injunction that was blocking DOGE’s access to sensitive federal data.

Federal Contractor

“Modernizing Defense Acquisitions and Spurring Innovation in the Defense Industrial Base,” was issued on April 9, 2025. Its primary objective is to overhaul the Department of Defense’s (DoD) acquisition processes to enhance speed, flexibility, and innovation.

In summary, Executive Order 14265 mandates a series of reforms within specified timeframes to modernize the DoD's acquisition processes, emphasizing speed, flexibility, and the integration of commercial innovations. Top of Form

No known lawsuits challenging Executive Order 14265

Federal Contractor

It mandates a comprehensive overhaul of the Federal Acquisition Regulation (FAR) and its agency-specific supplements to eliminate unnecessary provisions and streamline the federal procurement process. Could have a major impact on Federal Contractors' contracting terms with the federal government. It also could require the reallocation of internal resources to negotiate a new swath of federal contracts, or amendments for existing contracts, and the flowdown obligations of lower tiered subcontractors.

The FAR and its supplements are extensive; identifying which provisions are non-essential yet still critical for certain operations can be complex. So while the EO sets ambitious goals for procurement reform, achieving these goals remain to be seen.

No known lawsuits filed that challenge Executive Order 14275

Federal Contractor

The order aims to eliminate Diversity, Equity, and Inclusion (DEI) programs within the Department of Defense (DoD) and the U.S. Coast Guard, asserting that such initiatives undermine meritocracy and military cohesion.

Abolition of DEI Offices: All DEI offices and related programs within the DoD and the Department of Homeland Security (with respect to the Coast Guard) are to be dismantled. Prohibition of certain theories, such as the promotion or teaching of: "divisive concepts," including race or sex stereotyping and scapegoating. Federal Contractors are not DoD but often work closely with DoD and DHS. If your policies, programs, or even brochures are glaringly out of sync with this EO, it will be conspicuous and might even elicit comment from your Govt. point of contact. DEI policies should be widely inclusive and tethered to providing improved business outcomes, including better goods and services.

E.K. et al. v. Department of Defense Education Activity (E.D. Va., 1:25cv00637) Filed: April 15, 2025, by the ACLU National, along with ACLU affiliates in Virginia and Kentucky (Plaintiffs: Twelve DoDEA students (pre-K through 11th grade) stationed globally with military alleging that DoDEA, under direction from EO 14185 (along with EOs 14168 and 14190), illegally removed or banned books and curricula that discuss race, gender, and LGBTQ topics in violation of the First Amendment and students’ right to receive information by removing content like To Kill a Mockingbird, The Kite Runner, AP Psychology content, Pride Month materials, and more ) Status: PI Hearing held June 3, 2025, before Judge Patricia Tolliver Giles in the Eastern District of Virginia, addressing whether to block DoDEA’s actions and restore the removed materials. The case remains pending, with no ruling yet issued.

Federal Contractor

This order mandates a comprehensive overhaul of federal discretionary spending, including contracts, grants, loans, and real property leases, with the goal of enhancing transparency, reducing costs, and promoting accountability across federal agencies.

Within 30 days, agency heads must review all existing discretionary contracts and grants, prioritizing those involving educational institutions and foreign entities, to identify opportunities for termination, modification, or renegotiation to reduce federal spending.

No lawsuits directly challenging Executive Order 14222 (“Implementing the President’s ‘Department of Government Efficiency’ Cost Efficiency Initiative”)—but there is related litigation against the broader Department of Government Efficiency (DOGE) framework—including challenges to aspects of DOGE that derive from EOs in that initiative (14158, 14219, etc.).

Federal Contractor

EO mandates that federal agencies remove barriers to sharing unclassified data among themselves. The order aims to enhance efficiency, reduce duplication, and improve the government's ability to detect overpayments and fraud

Agencies are required to ensure that designated federal officials have full and prompt access to all unclassified agency records, data, software systems, and IT systems. Agency heads must rescind or modify existing guidance that hinders the sharing of unclassified information between agencies; and reassess their classification policies to prevent unnecessary restrictions on information sharing.

Pallek v. Rollins (D.D.C., filed May 22 2025) (plaintiffs are a foodsecurity nonprofit, a privacy center, and SNAP recipients challenging USDA’s letter based on EO 14243 that mandates sharing state SNAP personal data with DOGE teams. They allege violations of 1) the Privacy Act (individual consent / access rules), 2) the Paperwork Reduction Act (no new data collection without approval), and 3) the APA (agency action is arbitrary & capricious). Status is that the TRO motion filed May 27, 2025 and heard June 3, 2025 remains pending.

Federal Contractor

Bans hiring based on DEI, and adds “constitutional loyalty” screening.

The EO’s emphasis on “dedication to the furtherance of American ideals” and loyalty to the Executive Branch is effectively screening for ideology or viewpoint, especially when embedded in credentials-based hiring.

No legal actions as yet

Federal Contractor

Mandates that federal agencies recognize only two sexes—male and female—defined strictly by biological sex assigned at conception. The order directs agencies to replace references to "gender" with "sex" in all official documents and communications, cease funding for gender-affirming care, and prohibit individuals from using single-sex, federally funded facilities that align with their gender identity rather than their biological sex. Additionally, it instructs the Attorney General to issue guidance correcting what it describes as a misapplication of the Supreme Court's decision in Bostock v. Clayton County (2020) concerning sex-based distinctions in federal activities.

Federal contractors do not enjoy the same immunity from suits as the federal government. Discontinuing benefits, including gender-affirming care, for employees, could raise litigation risks.

Moe v. Trump (D. Mass.) – TRO (Jan 30 2025) stops transfers and gender-care cuts for trans women in federal prisons. Not nationwide; Kingdom v. Trump (D.D.C.) – Preliminary injunction (Jun 3 2025) bars EO 14168’s care restrictions nationwide for all incarcerated people with gender dysphoria. THIS NATIONWIDE PI COULD BE AT RISK DUE TO TRUMP v. CASA; Orr v. Trump (D. Mass.) – Nationwide injunction (Apr 18 2025) blocks the State Department from dropping gender-marker options on passports. Now a certified class. THIS NATIONWIDE PI COULD BE AT RISK DUE TO TRUMP v. CASA; San Francisco AIDS Foundation v. Trump (N.D. Cal.) – LGBTQ advocates challenge EOs 14168/14151/14173 on First- and Fifth-Amendment grounds. Ongoing, no injunction yet; National Urban League v. Trump (D.D.C.) – Civil-rights coalition brings similar constitutional/APA claims against the same EOs. Ongoing, no injunctive relief yet; Doctors for America v. OPM & Schiff v. OPM (D.D.C.) – Courts ordered HHS, CDC, and FDA to restore scrubbed gender-health webpages while APA/free-speech suits proceed. Interim restoration order only with merits determination still pending; Rhode Island Latino Arts v. NEA (D.R.I.) – Arts groups fight NEA’s “no gender ideology” funding ban. Judge denied preliminary relief after NEA paused enforcement. Case continues, no injunction.

Federal Contractor

Directs the Department of Defense to revise policies to exclude individuals who identify with a gender different from their biological sex from military service. The order cites concerns over unit cohesion, mental and physical readiness, and overall military effectiveness.

The order declares that identifying as a gender different from one's assigned sex conflicts with a soldier's commitment to an honorable, truthful, and disciplined lifestyle. It further states that the use of pronouns inconsistent with one's assigned sex compromises the ability of the government to establish high standards for troop readiness, lethality, cohesion, honesty, humility, uniformity, and integrity. So it casts transgender identification as a moral or character failure. While Executive Order 14183 specifically targets military service, its underlying principles may influence federal contractors, especially those providing services to the Department of Defense. Contractors may be expected to align their policies with the order's emphasis on biological sex, potentially affecting workplace practices related to transgender employees.

Potential conflict with Title VII and Bostock decision; casts transgender identity as incompatible with integrity. Ireland v. Hegseth, 1:25-cv-01918 (D.N.J.) (Plaintiffs: Master Sgt. Logan Ireland & Staff Sgt. Nicholas Bade, both active-duty Air Force members (challenging EO 14183/14168, which reinstated a ban on transgender individuals serving in the military. Plaintiffs allege violations of the Fifth Amendment (equal protection and due process), claiming the EO is arbitrary, overbroad, and lacks rational basis) Status: The case was voluntarily dismissed without prejudice by the plaintiffs on May 15, 2025) ; Shilling v. Trump, 2:25-cv-00241 (W.D. Wash.) (Plaintiffs: Commander Emily Shilling and other active-duty transgender (challenging EO 14183/14168, alleging it reinstates a ban on transgender service. Claim violations of Fifth Amendment equal protection, due process, and First Amendment privacy and expression rights); Status: on March 27, Judge Benjamin Settle issued a nationwide preliminary injunction, halting enforcement of the transgender service ban pending full resolution; Case remains active; briefing and discovery ongoing). THIS NATIONWIDE PI COULD BE AT RISK DUE TO TRUMP v. CASA; Talbott v. Trump, 1:25-cv-00240 (D.D.C.) (Plaintiffs: A cohort of active-duty transgender service members across Army, Navy, Air Force, Marines (challenging EO 14183/14168, alleging the ban violates Fifth Amendment equal protection and due process, as well as Fourth Amendment rights, and possibly APA procedural defects); Status: on March 18, Judge Reyes granted a preliminary injunction, enjoining enforcement of the EO starting at 10:01 a.m. EDT on March 21. The order was briefly stayed but then went into full effect as scheduled. IF THE PI IS NATIONWIDE IT COULD BE AT RISK DUE TO TRUMP v. CASA;

Federal Contractor

Specifically targets federal government transactions. It aims to improve oversight of payments flowing in and out of the United States General Fund, which encompasses federal disbursements such as benefits, grants, loans, and vendor payments. There is no indication that the order seeks to monitor or track private financial transactions beyond those involving federal funds. The focus remains on ensuring that taxpayer dollars are used appropriately and that federal payments are accurate and legitimate

Executive Order necessitates the sharing of certain payment-related data but includes provisions to ensure that such activities comply with existing privacy protections. The order does not extend its oversight to private financial transactions unrelated to federal disbursements

No active lawsuits directly challenging EO 14249

Federal Contractor

This order introduces a stringent deregulatory framework aimed at reducing the federal regulatory burden on businesses. This should be read in conjunction with EO# 14275 which directs the gutting of FAR and DFAR.

Key Provisions of EO 14192 require that for every new regulation proposed, federal agencies must identify at least 10 existing regulations for repeal. This is a significant escalation from the previous 2-for-1 policy implemented during President Trump's first term.

No legal challenge as yet.

Federal Contractor

Initiates a comprehensive review of federal law enforcement and intelligence activities over the preceding four years, aiming to identify and address instances where federal power may have been used to target political opponents or suppress constitutionally protected activities

EO 14147 mandates a thorough review of federal prosecutorial and enforcement actions taken between January 20, 2021, and January 20, 2025. It could have a chilling effect on future investigations and enforcement actions; or it could indirectly sway federal investigators and enforcement agents to find outcomes consistent with the Executive Branch's view.

John & Jane Does v. DOJ (D.D.C. No. 1:25-cv-00325, filed Feb 4 2025) – Nine anonymous FBI agents tied to the Jan 6 and Mar-a-Lago probes allege EO 14147’s “weaponization” review targets them for a purge, violating civil-service protections and due-process rights

Federal Contractor

This order directs federal agencies to cease the procurement and distribution of paper straws within federal facilities and to eliminate policies that disfavor plastic straws.

Federal contractors with existing long-term contracts supplying paper straws to government agencies with no contract exit clause short of force majeure (typically a very high bar to meet in courts) may be affected by this executive order.

No legal challenge as of June 25, 2025

Gen. Corporate/Labor&Empl.

Requires Department of Commerce and other agencies to coordinate U.S. technical, financial, and diplomatic resources to accelerate the global deployment of U.S.-made AI systems

Exported US-AI applications should focus on education, healthcare, and agriculture.

No Litigation as yet

Gen. Corporate/Labor&Empl.

Authorizes expedited permitting on federal lands for data centers

Streamlines environmental reviews by directing agencies to create exemptions expedite build out of data centers.

No litigation as yet

Gen. Corporate/Labor&Empl.

Revokes 120 Biden-era EOs.

Executive Order 14148 revokes a vast set of Biden-era policies, particularly those related to DEI, LGBTQ+ rights, climate, and immigration. It defines DEI as antithetical to merit and frames it as a form of ideological favoritism.

Northern Alaska Environmental Center v. Trump U.S. District Court, D. Alaska • No. 3:25-cv-00038 • Filed Feb 19 2025 Environmental groups (NAEC, Alaska Wilderness League, NRDC, etc.) challenge Executive Order 14148, which re-opens huge portions of the Arctic, Pacific, Atlantic and Gulf of Mexico Outer Continental Shelf for oil-and-gas leasing. No nationwide injunction as yet and less likely to be granted in light of Trump v. CASA.

Gen. Corporate/Labor&Empl.

Repeals a range of federal green energy tax credits and incentives, including those supporting wind, solar, hydrogen, and sustainable building initiatives.

Corporations that invested in green technologies relying on these now-revoked incentives should reassess their financial and operational plans accordingly. Also, while EO#14315 does not repeal EV vehicle credits. the One Big Beautiful Bill Act, signed into law July 4, 2025, does eliminate federal EV tax credits. Companies offering employee EV incentive programs or subject to state EV mandates will not be able to take advantage of federal credits after September 2025.

No litigation as yet.

Gen. Corporate/Labor&Empl.

180-day DOJ pause; SEC still active including SEC enforcement.

The FCPA remains a valid federal law, and bribery of foreign officials is still illegal. The executive order temporarily halts DOJ enforcement but does not repeal the law. The Securities and Exchange Commission (SEC), which enforces the FCPA's civil provisions, has not been directed to pause its enforcement activities. Therefore, companies may still face civil enforcement actions from the SEC .

None.

Gen. Corporate/Labor&Empl.

New advisory body on faith rights.

Private sector general counsel should be aware of potential increases in religious liberty claims from employees. This may include requests for religious accommodation, objections to certain workplace policies on religious grounds, or claims of religious discrimination.

None

Gen. Corporate/Labor&Empl.

Expands ideological checks & removals visa holders

For corporations with a significant number of employees holding visas from countries identified as high-risk, the executive order presents several challenges:

Taal v. Trump. Northern District of New York (3:25 cv 00335) (claims EO 14161 (and EO 14188) for allegedly chilling First Amendment–protected speech by threatening visa revocations and deportation for expressing “hostile attitudes” toward U.S. or Israeli policies . Plaintiffs include noncitizen and citizen activists on college campuses; case ongoing, though one petitioner self-deported; AAUP v. Rubio (1:25 cv 10685) (claims EO 14161 empowers "ideological deportation" for political expression—violating First and Fifth Amendment rights, as well as due process. Lawsuit filed mid-March; seeking declaratory and injunctive relief; Chung v. Trump & Similar Student Actions (Court: S.D.N.Y. (1:25 cv 02412 + multiple related cases) claim student plaintiffs like Yunseo Chung and others detained or facing deportation solely for expressing anti-war or pro-Palestinian views—suffered First Amendment violations and lack of due process. Complaints filed March 18 & 24, seeking nationwide injunctions (unlikely to be granted due to Trump v. CASA);

Gen. Corporate/Labor&Empl.

EO raises concerns about the independence of legal interpretations within executive agencies and the potential for increased political influence over legal proceedings; and mandates that all executive-branch personnel—including staff at independent agencies like the FEC—must defer to the legal interpretations of the President or Attorney General and prohibits staff from interpreting laws independently. The EO also requires independent agencies to submit significant rules for White House review and creates White House liaisons in those agencies. Extends presidential oversight to independent regulatory agencies.

Agencies impacted (SEC, FTC, CFPB, FEC, DOJ, FERC).

Democratic National Committee (DNC), DCCC & DSCC v. Trump et al. (Court: D.D.C., Case No. 1:25cv00587 Filed: February 28, 2025 (challenges Section 7 of EO 14215). March 14, 2025: Trump and AG moved to dismiss for lack of standing and failure to state a claim. FEC filed a separate motion on March 21. June 3, 2025: The court granted both motions to dismiss filed by the President, AG, and FEC/Commissioners. The case is seemingly closed.

Gen. Corporate/Labor&Empl.

Suspends contracts/clearances for 5 firms for taking on matters perceived as adverse to Executive Branch’s position, including regarding DEI practices.

All enjoined; retaliation issues. Some of the injunctions nationwide raising concerns about ongoing enforceability in light of Trump v. CASA Inc. (6-27-25). Corporations should take note in terms of who they take on as clients and/or the nature of services provided if deemed contrary to the Trump Administration objectives.

Wilmer Hale v. Executive Office of the President (D.D.C. No. 1:25-cv-00917) (May 27 2025: permanent injunction issued. Plaintiff seeking nationwide ban; Jenner & Block v. DOJ (D.D.C. No. 1:25-cv-00916) (May 23 2025: granted summary judgment, declared EO 14246 unlawful, and entered a nationwide permanent injunction). THIS NATIONWIDE PI COULD BE AT RISK DUE TO TRUMP v. CASA.; Perkins Coie v. DOJ (D.D.C. No. 1:25-cv-00716) May 2 2025)( permanently enjoined EO 14230 nation-wide). THIS NATIONWIDE PI COULD BE AT RISK DUE TO TRUMP v. CASA.; Susman Godfrey v. EOP (D.D.C. No. 1:25-cv-01107) (TRO issued; the firm now seeks to permanent nationwide injunction). THIS NATIONWIDE PI COULD BE AT RISK DUE TO TRUMP v. CASA.

Gen. Corporate/Labor&Empl.

AI systems procured by the federal government must meet a new standard of “ideological neutrality.”

Requires that any AI systems procured by the federal government must meet a new standard of “ideological neutrality,” defined in part by the rejection of DEI as “one of the most pervasive and destructive of these ideologies.” This EO prohibits AI providers from encoding “partisan or ideological judgments” into model outputs—yet simultaneously establishes anti-DEI and pro-nationalist baselines as the standard for neutrality

No litigation as yet.

Gen. Corporate/Labor&Empl.

Abolishes federal DEI; FCA “illegal DEI” and treble damages;

Executive Order 14151: Mandated the termination of all DEI-related programs, positions, and contracts within federal agencies, labeling such initiatives as discriminatory. Executive Order 14173: Revoked EO 11246, effectively ending affirmative action requirements for federal contractors, and directed agencies to eliminate DEI programs deemed unlawful. Federal Contractors' certification of "compliance" will be subject to FCA enforcement, and private sector DEI initiatives could face legal challenges if DEI programs are perceived as discriminatory under the new federal framework.

EO 14150 & EO14173 National Association of Diversity Officers in Higher Education v. Trump (D. Md.) – Nationwide PI granted (Feb 21); stayed March 14 by Fourth Circuit. THIS NATIONWIDE PI COULD BE AT RISK DUE TO TRUMP v. CASA; National Urban League et al. v. Trump (D.D.C.) – Challenge to EO 14151, 14168, 14173; PI denied May 2, 2025 and under appeal by plaintiffs; Chicago Women in Trades v. Trump (N.D. Ill.) – Nationwide PI issued April 14, 2025. THIS NATIONWIDE PI COULD BE AT RISK DUE TO TRUMP v. CASA; San Francisco AIDS Foundation v. Trump (N.D. Cal.) – PI granted June 9 blocking grant restrictions. THIS NATIONWIDE PI COULD BE AT RISK DUE TO TRUMP v. CASA; National Association of Diversity Officers in Higher Education, et al. v. Trump (Feb. 3, 2025, challenging directing agencies to terminate “equity related” contracts; Shapiro et al. v. DOI, E.D. Pa., Case No. 25cv763 — addresses DEI provisions Feb 21: District Court issued a nationwide preliminary injunction, blocking these provisions March 14: Fourth Circuit stayed the injunction, allowing the government to resume enforcement during appeal Status: Termination EO 14151, 14173 Blocked Nationwide in MD and IL (stayed by 4th Circuit) Certification EO. THIS NATIONWIDE PI COULD BE AT RISK DUE TO TRUMP v. CASA.

Gen. Corporate/Labor&Empl.

Kills Biden global LGBTQ-rights memo etc. Targets the revocation of Arctic/Ocean protections for the Outer Continental Shelf

Signals wider rollback; HR audit.

Northern Alaska Environmental Center et al. v. Trump: Court: D. Alaska (3:25 cv 00038) claims that EO 14236 targets the revocation of Arctic/Ocean protections for the Outer Continental Shelf—insisting that only Congress can reverse such withdrawals under the OCS Lands Act; Susman Godfrey LLP v. Executive Office of the President Court: D.D.C. (1:25 cv 01107) Filed: April 2025 claims sections of EO 14236 are harmful to advocacy firms and claims to have been targeted under the rescinded EO 14236 provisions. The court granted a TRO on April 15, 2025, preventing enforcement of sections 1, 3, & 5 of EO 14236 and ordering federal agencies—including DOJ and OMB—to disregard those provisions. The injunction restrains the agencies as it pertains to enforcement of these sections of the EO. We should expect challenges to the restraint under Trump v. CASA.

Gen. Corporate/Labor&Empl.

Addressing Security Risks from Price Fixing and Anti-Competitive Behavior in the Food Supply Chain.” The EO establishes a task force comprised of the Attorney General and FTC Chairman to investigate food-related industries, with a particular focus on foreign-owned or controlled entities that participate in “the American food supply chain[.]" These food-adjacent or food-supportive industries include the “meat processing,” “seed,” “fertilizer,” and “equipment” sectors.

Antitrust, price/output coordination, wage fixing

There is already significant private antitrust litigation pending against major meat and poultry producers including Cargill, Tyson, and Smithfield. Hundreds of millions of dollars have been paid to date. While there are multiple classes involved, the core allegations are familiar: price fixing, supply restrictions, and even wage fixing. Also, many of these food adjacent markets have not historically been front and center for DOJ or FTC enforcement. DOJ did investigate Agri Stats, a third-party agricultural benchmarking platform alleged to have served as a hub that permitted the competing meat and poultry producers (“spokes”) to coordinate their prices, adjust/restrict output, and set wages. It is not clear that the agencies previously focused on the broader ecosystem of companies supporting the food supply chain.

Gen. Corporate/Labor&Empl.

EO#14337 revokes Biden's EO#14036 issued in 2021, which had directed federal agencies to prioritize prosecution of illegal wage-fixing, and also to crack down on overly broad and restrictive non-compete agreements such that employees at a certain level were restricted in their mobility in the labor market.

Revocation of EO#14036 does not remove legal restrictions on wage-fixing at the federal or state level, nor does it allow for broad and all-encompassing non-competes. First, wage-fixing remains unlawful under the Sherman Act. EO#14337 merely de-prioritizes enforcement. Second, several state antitrust laws prohibit extensive non-competes at certain job levels, and other states have similar limitations on how restrictive non-competes can be. Finally, even though EO#14337 reduces the priority of enforcement of these labor-related antitrust limitations, the statute of limitations on violations, particularly if the violations are ongoing, could extend beyond the current Trump Administration. So just tread carefully as a General Counsel and/or Head of HR.

No litigation as yet

Gen. Corporate/Labor&Empl.

Ends fed $$ for minor gender-affirming care.

This could influence the coverage policies of private insurers, especially those participating in ACA marketplaces or receiving federal funds

PFLAG, Inc. v. Trump, 8:25-cv-00337 (D. Md.) ( Plaintiffs are trans youth, families & providers seeking to block the EO for unlawfully withholding federal funds from hospitals and clinics providing gender-affirming care to minors). Nationwide TRO issued Feb. 13, 2025 blocking EO 14187. THIS NATIONWIDE PI COULD BE AT RISK DUE TO TRUMP v. CASA; • Washington v. Trump Court: W.D. Wash. (2:25 cv 00244) Filed: February 7, 2025 by states (WA, MN, OR) + physicians claim that EO violates Equal Protection, Tenth Amendment, and APA by coercing providers and using emergency powers. Status: Preliminary injunction issued Feb 19, blocking enforcement in the 4 plaintiff states; Additional Litigation: Attorneys General of MI, MN, OR, WA, and physicians also filed in D. Md. and W.D. Wash and advocacy groups like the ACLU and Lambda Legal joined as amici or co-plaintiffs. The courts recognize serious constitutional and procedural issues resulting from withholding medical funding and framing gender-affirming care as “mutilation.”

Gen. Corporate/Labor&Empl.

EO 14278: Orders Labor, Education & Commerce to overhaul federal training and apprenticeship programs and to issue guidance helping employers open jobs to non-degree applicants. EO emphasizes the importance of skilled trades and seeks to elevate their status as viable and lucrative career paths; EO 14281: Ends disparate-impact liability at the federal level. Directs every agency to stop using disparate-impact analysis under statutes such. Section 7(b) also, encourages employers to adopt more inclusive hiring practices by considering non-degree holders for positions where a college education is not essential, thereby promoting equal access to employment opportunities based on merit and skills.

The issuance of Executive Orders 14278 and 14281 signifies a federal shift towards promoting employment opportunities based on skills and merit, irrespective of formal educational attainment. Per EO 14278, employers are encouraged to adapt their hiring and compliance practices to align with these new directives, Per EO 14281, federal employers are prohibited from engaging in disparate-impact analysis, and state/private sector employers are encouraged to do the same. Employers are to "promote equal access to employment regardless of whether an applicant has a college education, where appropriate."

None.

Law Enforcement

This EO serves as a blueprint for the federal takeover of public safety functions in Washington, D.C., using crime control and urban beautification as legal justification

Though framed as a public welfare effort, the structure, scope, and language reveal a de facto federal law enforcement regime over the District, enabled through an unprecedented blend of federal prosecutorial authority, security agency coordination, and local law enforcement subordination.

No litigation as yet.

Law Enforcement

It’s all about DOGE RIFs but excludes law enforcement from the categories of employees subject to RIF.

As it pertains to law enforcement, there are none to flag at this time.

A broad coalition led by the American Federation of Government Employees (AFGE), along with other labor unions, nonprofit organizations, and local governments (including San Francisco, Chicago, Baltimore, Harris County, and King County), sued in the Northern District of California on April 28, 2025, arguing that EO 14210—which mandates mass layoffs, hiring freezes, and agency restructuring under the newly created “Department of Government Efficiency”—violates the Constitution’s separation of powers and federal labor laws Supreme Court. A temporary injunction was granted by the district court and upheld by the 9th Circuit. But on July 8, 2025, the injunction was essentially lifted by the Supreme Court thus allowing the EO to proceed pending the ongoing litigation. Related litigation includes Maryland et al. v. USDA and New York v. Kennedy, filed in D.C. and Rhode Island, respectively, which specifically challenge cuts at HHS and other agencies and resulted in a preliminary injunction at the district level. In addition, unions are separately contesting OPM’s RIF implementation and deceased bargaining exemptions—for instance, the National Treasury Employees Union filed in D.C. on February 12, 2025—claiming the actions exceed statutory authority.

Law Enforcement

DoD and DOJ are directed to surge military-grade equipment, training, and even personnel into local jurisdictions, including non-lethal capabilities and potentially intelligence-linked resources being made available to local departments. Departments must prepare for legal, reputational, and community response challenges when using military gear or joint operations involving federal personnel.

DOJ and federal agencies will issue “aggressive policing” best practices to be adopted locally. Agencies may feel pressured to align with federal enforcement styles, potentially displacing reform-oriented models. More training opportunities will be provided, but they may prioritize militarized tactics or federal enforcement priorities over local/community-driven ones. Command staff must assess whether federal training curricula conflict with existing accountability or community policing protocols. Local officials, police chiefs, or sheriffs could become targets of federal prosecution or civil enforcement if they resist DOJ guidance or maintain reform-oriented practices (e.g., limits on use-of-force, sanctuary policies, DEI).

None as yet

Law Enforcement

Attorney General must seek federal death penalty in cases that might be traditionally left to states—especially officer killings or undocumented perpetrators. A key provision orders the Attorney General to reclassify individuals whose federal death sentences were commuted to life imprisonment as “high-risk offenders” and transfer them to the nation’s most secure facilities, including supermax or administrative maximum units such as ADX Florence.

While the EO primarily addresses federal incarceration policy, it calls on the Department of Justice and the Department of Homeland Security to expand coordination with state and local law enforcement agencies for fugitive apprehension and joint task force operations.

Taylor v. Trump 1:25-cv-01161 | U.S. District Court for the District of District of Columbia: Filed Date: April 16, 2025: twenty-one of the 37 prisoners with commuted death sentences filed suit challenging the AG's bypassing of statutorily-required procedures for reassignment of prisoners to transfer 37 inmates to ADX Florence, the harshest unit in the federal prison system.

Law Enforcement

The primary objective of the EO is to enforcement the immigration laws through the deportation of people living in the US illegally. To rapidly expand ICE/DHS agents, the EO encourages state and local jurisdictions to enter formal agreements with ICE under Section 287(g) of the Immigration and Nationality Act.

The deputization of local law enforcement effectively turns local police into ICE agents. This blurs the line between local policing and federal immigration enforcement. Law enforcement, whether deputized or not, should expect an erosion of community trust in their local police.

EO 14159 is currently facing multiple legal challenges across various federal courts. These lawsuits argue that it: (1) coerces states/jurisdictions by threatening federal funding; (2) expands deportation powers without due process; and (3) restricts attorney access to detained individuals. In City and County of San Francisco v. Trump, filed in February 2025, several “sanctuary” jurisdictions—including San Francisco, Santa Clara County, and Portland—argue that the EO unlawfully conditions federal funding on immigration enforcement cooperation, violating the Tenth Amendment, the Spending Clause, and the APA. A preliminary injunction was granted in April 2025. A related case, City of Chelsea v. Trump, filed in Massachusetts, raises similar claims. Separately, Make the Road New York v. Huffman, filed in January 2025, challenges the EO’s expansion of expedited removal as a violation of due process and immigration law. Additional lawsuits, including Amica Center for Immigrant Rights v. DOJ and American Gateways v. DOJ, target EO 14159’s impact on immigrants’ access to legal counsel while in detention. As of July 2025, these cases remain active and/or are in the midst of an appeal, with at least one preliminary injunction in effect.

Law Enforcement

EO claims that DC's level of lawlessness poses a risk to the federal functions, including hindering recruitment and retention such that the levels of crime undermine critical government functions.

Certain crime statistics cited in the EO could not be independently corroborated, including the statement that DC's crime was “highest than all 50 states,” and that DC was one of the “top 20% most dangerous cities in the world.”

On August 15, 2025, D.C. filed a lawsuit against the Trump administration, alleging EO#14333's unlawful assertions of authority pose an immediate and irreparable harm to the District, specifically to the chain of command of MPDC thus endangering public and officer safety. The District is seeking preliminary and permanent injunctions.

Law Enforcement

EO# 14339 builds on EO# 14333 (declaring a crime emergency in D.C.), directs for an online portal seeking applications from the public to join in federal law enforcement efforts in D.C., directs Sec'y of Defense to create a specialized unit within the D.C. National Guard to carry out local law enforcement under the direction of the federal government.

Embedded in this EO is the threat of federal and local law enforcement if HUD landlords fail to maintain the premises in sanitary conditions of their buildings AND if they fail to "restrict tenants who engage in criminal activity." The EO states that violations of these HUD provisions will be referred to the AG and federal and local law enforcement. There are D.C. tenant protections against landlords evicting tenants based solely on an arrest or for victims of domestic violence. Nevertheless, the EO calls for referrals to federal and local law enforcement for HUD violations.

On September 4, 2025, DC sued the Trump administration challenging the deployment of thousands of federally controlled National Guard troops in Washington, D.C. The suit argues that this deployment amounts to an unauthorized and involuntary military occupation of the city. The lawsuit does not directly challenge Executive Order 14339, but is closely related, as the National Guard deployments appear to be one of the key federal actions stemming from or justified by the EO 14339 framework.

Miscellaneous

Fast-tracks domestic pharma plants.

FDA will ramp up inspections of foreign manufacturing facilities mandated to supply U.S. markets. Tariffs could significantly increase pricing on imported drugs.

No known lawsuits directly challenging EO 14293

Miscellaneous

The EO targets projects that promote values seen as conflicting with the Trump Administration's view of "American values."

Organizations with initiatives supporting or promoting topics such as, critical race theory, immigration, racial preferences, transgender initiatives, or other social movements deemed progressive will not be funded. Also, NGOs/nonprofits that do receive funding are expected to be able to demonstrate progression toward stated objectives and to reduce their administrative costs.

No litigation as yet

Miscellaneous

Speeds NRC permits; DOE test beds; industrial base build.

Qui-tam risk for overbilling

No known lawsuits as of June 25 for 14299, 14300, 14301, or 14302

Miscellaneous

Mandates aligning U.S. drug prices with the lowest prices paid in similarly developed OECD countries.

Different countries set prices based on a range of factors—list prices, rebates, negotiated discounts, GDP adjustments, or health-technology assessments—making direct comparisons unreliable. HHS clarified MFN applies only to single-source brand-name drugs without generic competition, further restricting and complicating comparisons. Qui-tam risk for overbilling.

No lawsuits directly challenging EO

Miscellaneous

The order directs federal agencies to reshape historical narratives presented in federally funded institutions, particularly targeting the Smithsonian Institution and national monuments. It mandates the removal of exhibits and narratives deemed "divisive" or focused on "race-centered ideology" and calls for the restoration of monuments and memorials removed since 2020.

The executive branch possesses certain powers to influence federal agencies and their operations. However, the extent to which it can dictate specific historical narratives is constrained by legal and constitutional considerations.

No lawsuits filed yet as of June 20, 2025, but it does raise viewpoint based discrimination under the First Amendment. This EO seemingly would punish recount of parts of US history (e.g., African American, Women), but spares others’ history (e.g., Jewish).

Miscellaneous

Federal agencies are directed to review all existing regulations that impose criminal penalties for nonviolent, technical, or paperwork violations, and rescind or modify such penalties where civil or administrative remedies would suffice. Mens rea (intent) must be rquired.

Less risk of criminal liability for unintentional regulatory missteps; more reliance on civil penalties.

No lawsuits currently challenging Executive Order 14294

Trade/Tariffs

EO#14324 eliminates the duty-free exemption for imported goods from all countries valued at $800 or less effective August 29, 2025.

For fast-moving-consumer goods, like many ecommerce goods, USA buyers very likely are the Importers of Record and will be responsible for paying the taxes on the imported goods now that the exemption has been eliminated. Processing times also could be adversely impacted -- i.e., formal customs entries required.

Detroit Axle v. CIT specially challenges the elimination of the de minimis exemption for goods imported to the USA from China (EO#14256).

Trade/Tariffs

EO 14257 imposes new tariffs aimed at addressing longstanding trade imbalances. A 10% baseline tariff was imposed on most imports from countries with longstanding trade imbalances. And then even higher tariffs will be applied to the following countries/jurisdictions: China: 34%, Vietnam: 46%, India: 26%, EU: 20%, Japan: 24%, South Korea: 25%

Tit-for-tat escalation risk.

Part of V.O.S. appeal. On August 29, 2025, the Federal Circuit found that IEEPA did not clearly authorize broad, wartime-style tariff measures as seen in various EOs, such as EO#14256, in particular. On Sept. 9, 2025, the U.S. Supreme Court granted cert. on September 9, 2025, to review federal appellate court rulings that found President Donald Trump exceeded his authority in imposing sweeping tariffs under emergency powers.

Trade/Tariffs

Extends the suspension timeline initially set under EO 14266, pushing deadlines out farther (e.g. extending suspension from July 9 to August 1, 2025).

EO# 14298 setting reciprocal tariff rates for China remains unaffected by this EO.

No litigation as yet.

Trade/Tariffs

The EO lifts the United States’ comprehensive sanctions program against Syria by revoking six prior executive orders and terminating the national emergency underpinning broad economic restrictions.

Bashar al-Assad remains a Blocked Party (i.e., SDN), as does his senior Syrian government officials, and individuals and entities tied to human rights abuses, terrorism, and narcotics trafficking. Also, BIS has not yet updated the EAR (i.e., Export Administration Regulations). This means that most exports and reexports to Syria involving US goods still require a special license and remain subject to a general policy of denial. BIS is expected to relax the EAR requirements regarding Syria by Q3'25.

None as of yet.

Trade/Tariffs

Announces sweeping tariffs: 25 % on most Canadian goods, 10 % on energy products. EO 14197 (3 Feb) – Hits the pause button, delaying the start date to study economic fallout. EO 14226 (2 Mar) – Softens the blow for the U.S. auto sector by trimming or deferring tariffs on critical cross-border automotive inputs. EO 14231 (6 Mar) – Adds a carve-out: temporary exemptions for USMCA-compliant goods, shielding roughly 38 % of Canadian exports from the new duties.

Canada hit back on 13 Mar 2025 with 25 % tariffs on $29.8 B in U.S. goods, pulled U.S. liquor from store shelves, and froze new provincial contracts with American firms—raising costs in autos, agriculture, and energy despite narrow USMCA exemptions.

Webber (tribal members) and V.O.S. (importers) suits attack the tariff program—V.O.S. won a nationwide CIT injunction (now stayed); together they drag EOs 14197, 14226 and 14231 into court. On August 29, 2025, the Federal Circuit found that the IEEPA did not clearly authorize broad, wartime-style tariff measures as seen in various EOs, such as EO#14256, in particular. On Sept. 9, 2025, the U.S. Supreme Court granted cert. on September 9, 2025, to review federal appellate court rulings that found President Donald Trump exceeded his authority in imposing sweeping tariffs under emergency powers.

Trade/Tariffs

The EO further delays the implementation of higher tariffs on China until November 2025

Higher tariffs on imports from China announced in EO#14257 (April 2025) and EO#14298 (May 2025) are delayed until November 9, 2025.

No litigation as yet

Trade/Tariffs

Designates certain transnational criminal organizations, such as Tren de Aragua, as foreign terrorist organizations. This designation empowers U.S. authorities to impose sanctions and take legal actions against entities and individuals associated with these groups

Implement or update compliance programs to include screening of third-party vendors, drivers, and subcontractors against the SDN List. Legal Consultation: Seek legal advice to understand the full scope of EO 14157 and to ensure that your business operations remain compliant with U.S. laws and regulations.

No known legal actions at this time

Trade/Tariffs

Non-English CDLs not allowed.

The trucking industry is currently experiencing a significant shortage of qualified drivers, with estimates indicating a deficit exceeding 80,000 drivers nationwide.

No known lawsuits directly challenging

Trade/Tariffs

Temporarily reduces several of the previously imposed punitive tariffs on Chinese-origin imports. Codifies & phases new China list.

Long-term sourcing shift.

V.O.S. Selections v. U.S. (CIT) – May 28, 2025 ruling voided the “Liberation Day” tariff orders as beyond IEEPA; Federal Circuit stayed the decision pending appeal; Detroit Axle v. U.S. (CIT) – Importer seeks to block the de-minimis ban on China goods; case on fast track, no ruling yet (challenge to EO#14256). On August 29, 2025, the Federal Circuit found that the IEEPA did not clearly authorize broad, wartime-style tariff measures as seen in various EOs, such as EO#14256, in particular.

Trade/Tariffs

“Secondary tariffs” Trigger: Any country that buys Venezuelan oil on/after 2 Apr 2025. Penalty: 25 % tariff on all of that country’s goods entering the U.S. Process: Commerce decides if the country imported the oil; State then levies the tariff. Sunset: Tariff ends one year after the country’s last Venezuelan-oil import (or sooner if Commerce lifts it).

Implications of Imposing Secondary Tariffs EO 14245 is believed to be the first time that the U.S. has imposed “secondary tariffs” on countries' imports for purchasing the initially-tariffed item, in this case, Venezuela Oil.

No pending lawsuits directly challenging Executive Order 14245 (“Imposing Tariffs on Countries Importing Venezuelan Oil,” Mar. 24 2025)

Trade/Tariffs

25 % tariff announced (EO 14194), delayed (14198), softened for autos (14227), and partly waived for USMCA-compliant goods (~38 %) (14232). Mexico protests but hasn’t struck back.

Despite the tariffs, nearshoring in Mexico remains a viable strategy.

EO 14194: three main suits are now on the books against EO 14194’s Mexico tariffs V.O.S. Selections, Inc. v. Trump (CIT No. 25-00066, consolidated with State of Oregon v. DHS No. 25-00077) Importers plus 12 states attacked EO 14194 (and its Canadian/Chinese twins). Outcome: Court of International Trade permanently enjoined the order nationwide on May 28, 2025; the Federal Circuit entered a temporary stay the next day while the appeal proceeds. On August 29, 2025, the Federal Circuit found that the IEEPA did not clearly authorize broad, wartime-style tariff measures as seen in various EOs, such as EO#14256, in particular. On Sept. 9, 2025, the U.S. Supreme Court granted cert. on September 9, 2025, to review federal appellate court rulings that found President Donald Trump exceeded his authority in imposing sweeping tariffs under emergency powers. Learning Resources, Inc. v. Trump (D.D.C. No. 1:25-01248) Two educational-toy companies won a district-court injunction on May 29 that bars enforcement of the Mexican tariff against them; the government’s appeal is pending and the judge kept the case in D.C. rather than sending it to the CIT. Barnes v. United States (CIT No. 25-00043) A pro-se importer’s challenge was dismissed for lack of standing on May 23 2025.

Trade/Tariffs

Feb 1 – EO 14195: 10 % duty on designated Chinese goods and ends the de minimis exemption. Feb 5 – EO 14200: Pauses that exemption change while customs systems catch up. Mar 3 – EO 14228: Doubles the duty to 20 %. Apr 2 – EO 14256: Systems ready; de minimis elimination takes effect 2 May. Apr 8 – EO 14259: Jacks the tariff up again—ultimately as high as 90 %—to maximize pressure on targeted imports

Consumers face higher prices and potential shipping delays, while businesses absorb new import costs and paperwork—prompting firms like Shein and Temu to raise prices and shift logistics closer to U.S. buyers.

Imposing Duties on Chinese imports Legal action: EO: 14195: V.O.S. Selections v. U.S. (Court of International Trade) and Princess Awesome, LLC, challenge IEEPA tariffs issued via EO 14195 (and EOs 14200, 14228, 14256, 14259, etc.) (Status (May 28): CIT struck down tariffs as exceeding presidential authority under IEEPA. Government appealed; stay granted pending briefing) EO 14200, 14228, 14256, 14259 (no standalone challenges—but amendments to tariffs (like via EO 14256) remain part of the consolidated tariff litigation in V.O.S. and related cases). On August 29, 2025, the Federal Circuit affirmed the district court finding that the tariffs exceeded the President's powers under the IEEPA. The Court's ruling will take effect October 14, 2025. With respect to EO#14256, Detroit Axle v. CIT specially challenges the elimination of the de minimis exemption for goods imported to the USA from China. On Sept. 9, 2025, the U.S. Supreme Court granted cert. on September 9, 2025, to review federal appellate court rulings that found President Donald Trump exceeded his authority in imposing sweeping tariffs under emergency powers.