A federal judge in Boston struck down the Trump administration’s cancellation of roughly $600 million in teacher-training grants on Thursday, ruling that the Education Department’s directive violated federal law and was arbitrary and capricious. Judge Angel Kelley found the order hasty, found the department skipped the notice and comment the law required, and found it never weighed how heavily states, students, teachers and principals depend on the money. The reliance interests, she wrote, are “many, substantial, and deep-rooted.”
And the money is not coming back. Not because of anything in her opinion, but because of a Supreme Court order from April 2025 that most coverage of this ruling will not mention. Understanding why a party can win an Administrative Procedure Act case and still not get paid is the most useful thing to take from this decision, and it now governs every federal grant termination fight in the country.
What was cut
In February 2025 the Education Department eliminated about $600 million in teacher-training grants, describing them as supporting “divisive ideologies” including diversity, equity and inclusion. The cuts hit 31 grants under the Supporting Effective Educator Development program and 72 under the Teacher Quality Partnership program. Both programs exist to address teacher shortages.
Eight states including Massachusetts sued in the District of Massachusetts under the Administrative Procedure Act. Judge Myong Joun issued a temporary restraining order early in the case, finding the department had not properly explained its reasoning.
What the Supreme Court did in April 2025
The administration went to the Supreme Court, and on April 4, 2025 the Court granted a stay in Department of Education v. California, 5 to 4, in an unsigned opinion.
The majority did not say the cuts were lawful. It said the government was likely to succeed in showing that the district court lacked jurisdiction to order the grants continued. The reasoning ran through the Tucker Act, 28 U.S.C. § 1491(a)(1), which gives the Court of Federal Claims jurisdiction over suits founded on any express or implied contract with the United States. An order compelling the government to keep paying grant money, the Court indicated, is in substance a claim for money owed under an agreement, and that belongs in the Court of Federal Claims rather than a district court sitting in review of agency action.
That single procedural holding has reshaped a great deal of litigation since. A state can sue under the APA and win a declaration that an agency acted unlawfully. What it generally cannot get from that court is an order directing the Treasury to pay.
Why Judge Kelley’s ruling still matters
Because a declaration that agency action was unlawful is not nothing, and in this posture it is most of what the law makes available.
The APA directs a reviewing court to set aside agency action that is arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law. Judge Kelley made two findings under that standard.
The procedural one is that the department did not follow the required process for giving notice or accepting comment. An agency that changes a policy through what amounts to a directive, without the procedure Congress prescribed, has not done the thing the statute authorizes it to do.
The substantive one is the reliance finding, and it is the stronger half. Under settled administrative law an agency changing course must display awareness that it is changing position and must take into account serious reliance interests that its prior policy engendered. Grant recipients who hired staff, admitted cohorts of teacher candidates and built programs around multi-year federal awards are the textbook example. Kelley found the department never engaged with any of it. That is the kind of error that is difficult to cure on remand without actually confronting the facts.
The practical effect is that the policy is vacated. The department cannot rely on that directive going forward. If it wants to end these programs it has to start over and do it properly, and it has to reckon with the reliance interests on the record.
Where the money fight goes
To the Court of Federal Claims, if anywhere. A grantee seeking payment of terminated awards would file there under the Tucker Act, where the questions are contractual rather than administrative and the remedy is damages rather than vacatur. That is a slower, narrower and more expensive path, and it is the one the Supreme Court’s stay pointed to.
There is a second possibility. An agency that has had its directive vacated sometimes restores funding voluntarily rather than relitigate, particularly where the program is congressionally appropriated and the agency’s stated basis has been rejected. Nothing requires it here.
Why this keeps landing in Massachusetts
Because Massachusetts keeps filing, and because a state may sue where it is. The Attorney General has made the District of Massachusetts a principal venue for challenges to federal action, and the teacher-training case is one of a set. We track the active litigation between the Commonwealth and the federal government in our running tracker, which we are updating with this ruling.
The pattern across those cases is consistent and worth naming. States have done well on the administrative law merits, where agencies have moved quickly and documented poorly. They have done less well on remedies, because the Supreme Court’s emergency docket has repeatedly narrowed what a district court may order while a case proceeds.
What to watch
Whether the administration appeals to the First Circuit, and whether it seeks a stay while it does. Whether the Education Department attempts the same cuts again with a proper record, which is the course the ruling leaves open. Whether any grantee files in the Court of Federal Claims for the money itself. And whether the reliance-interest analysis in this opinion is picked up in the other grant cases, since it is the part most likely to be cited.
Common questions
What did the judge decide?
That the Education Department’s 2025 directive cutting about $600 million in teacher-training grants violated federal law and was arbitrary and capricious, because the department skipped required notice and comment and failed to consider substantial reliance interests.
Does the ruling restore the grant money?
No. The court vacated the policy. Claims for payment of terminated federal grants generally belong in the Court of Federal Claims under the Tucker Act.
Why can’t a district court order the money paid?
Because of the Supreme Court’s April 2025 stay in Department of Education v. California, which indicated the government was likely to show that a district court lacks jurisdiction under the APA to order continued grant payments, since such claims sound in contract.
What programs were affected?
Thirty-one grants under Supporting Effective Educator Development and seventy-two under the Teacher Quality Partnership program, both aimed at teacher shortages.
Can the administration try again?
Yes. The ruling faults the process and the failure to weigh reliance interests. A new action taken with proper procedure and a developed record would be evaluated on its own terms.
Judge Angel Kelley’s September 17, 2026 ruling and the quoted phrase “many, substantial, and deep-rooted” as reported by WBUR, the Boston Globe, NBC News and Education Week; this publication has not obtained the written decision. Grant program figures as reported. Department of Education v. California, 604 U.S. ___ (2025), decided April 4, 2025, described from the Court’s per curiam opinion. The Tucker Act provision is 28 U.S.C. § 1491(a)(1). The earlier temporary restraining order was issued by Judge Myong Joun. General information, not legal advice.