The EO directs foreign aid to be dispersed in a manner that aligns with U.S. foreign policy and places a 90-day pause on new foreign development assistance. During the period, department and agency leaders are required to review foreign aid programs for consistency with U.S. foreign policy and determine whether to continue, modify, or cease each program.

View the EO here.

Legal challenges:

• Personal Services Contractor Association v. Trump et al (D.D.C.), Case No. 1:25-cv-00469
  • Plaintiffs challenge Executive Order 14169 and subsequent actions that effectively suspended U.S. foreign aid and began dismantling USAID. The plaintiffs assert four causes of action: (1) violation of separation of powers against Trump, (2) violation of the Take Care Clause against Trump, (3) violation of the Administrative Procedure Act (APA) for arbitrary and capricious actions against all defendants except Trump, and (4) violation of the APA for actions not in accordance with law (including under the Impoundment Act and Anti-Deficiency Act) against all defendants except Trump. Injunctions requested.

• AIDS Vaccine Advocacy Coalition v. United States Department of State (D.D.C.), Case No. 1:25-cv-00400
  • Plaintiffs, AIDS Vaccine Advocacy Coalition (AVAC), and Journalism Development Network (JDN) sued for declaratory and injunctive relief to stop the implementation of the Executive Order and associated stop-work order. Plaintiffs allege the President’s actions are ultra vires (beyond his authority) and usurp legislative authority. They also allege the President has violated the Take Care Clause of the Constitution and that the stop-work orders are arbitrary and capricious in violation of the Administrative Procedure Act, the Anti-Deficiency Act (as an “unlawful reserve”), and the Impoundment Control Act.On Feb. 20, the court granted in part plaintiffs’ motion for enforcement of the court’s TRO “to the extent Defendants have not complied with the terms of the TRO,” but did not make a finding of contempt, citing “Defendants’ explicit recognition that ‘prompt compliance with the order’ is required.” The granted motion applies to this case and Global Health Council v. Trump.
• Global Health Council v. Trump (D.D.C.), Case No. 1:25-cv-00402
  • Plaintiffs challenge recent actions to defund USAID, lay off or furlough employees, and transfer the Agency to be under the State Department. Plaintiffs provide a detailed chronology of the actions, memoranda, and statements that the Administration has issued. Plaintiffs allege that neither the President, nor the Secretary of State, nor the USAID Administrator have the authority to unilaterally withhold already-appropriated funds, citing the Constitution and statutory law prohibiting the unilateral withholding: the Impoundment Control Act and the Anti-Deficiency Act. Plaintiffs also claim violations of the Administrative Procedure Act; that the Executive’s actions were arbitrary and capricious, and contrary to statutory and constitutional law. Injunctions requested.
• American Foreign Service Association v. Trump (D.D.C.), Case No. 1:25-cv-00352
  • Plaintiffs assert that executive actions to dissolve USAID or merge it with the State Department are unconstitutional violations of the separation of powers and the Take Care Clause; and unlawful under of the Administrative Procedure Act by exceeding statutory authority, violating the Further Consolidated Appropriations Act, and involving arbitrary and capricious abuses of discretion. A temporary restraining order and preliminary injunction requested.On Feb. 21, Judge Nichols issued an Order and Memorandum Opinion rejecting the preliminary injunction and dissolving the TRO. His reasoning included that plaintiffs do not face irreparable harm after a series of concessions from Deputy Administrator Marocco, and that they could pursue remedies with administrative bodies governing disputes.
• National Council of Nonprofits v. Office of Management and Budget (D.D.C.), Case No. 1:25-cv-00239-LLA
  • Plaintiffs seek a temporary restraining order against the Acting Director of the Office of Management and Budget’s memorandum that would “require every federal agency to temporarily pause” any agency activities “that may be implicated by [President Trump’s] executive orders.” Plaintiffs assert that the TRO is necessary to allow the Court “an opportunity to more fully consider the illegality of OMB’s actions,” alleging violations of the Administrative Procedure Act and the First Amendment.