The case of McMahon v. New York arose from the Trump Administration’s move to dissolve the Department of Education by executive order. President Trump directed Secretary of Education Linda McMahon to “take all necessary steps to facilitate the closure of the Department of Education and return authority over education to the States and local communities.” Acting on this directive, Secretary McMahon initiated a mass termination of over 50% of the Department’s workforce, with the stated goal of a departmental shutdown.
This executive action was immediately challenged in federal court by several states, led by New York, arguing that only Congress has the authority to abolish a Cabinet-level department established by statute. The United States District Court for the District of Massachusetts agreed, issuing a preliminary injunction on May 22, 2025, halting the mass firings and preventing further steps toward dismantling the Department while litigation proceeded.
On March 20, President Trump signed Executive Order 14242, pledging to close the agency. The order stated, in part:
Closing the Department of Education would provide children and their families the opportunity to escape a system that is failing them. Today, American reading and math scores are near historical lows. This year’s National Assessment of Educational Progress showed that 70 percent of 8th graders were below proficient in reading, and 72 percent were below proficient in math. The Federal education bureaucracy is not working.
He also stated in the order that the department “does not educate anyone” and “maintains a public relations office that includes over 80 staffers at a cost of more than $10 million per year.”
Supreme Court’s Holding
On July 14, 2025, the Supreme Court granted the federal government’s emergency application for a stay, effectively lifting the preliminary injunction. The Court’s order allows the Department of Education to proceed with the mass terminations and other steps toward closure, pending further review by the United States Court of Appeals for the First Circuit and any subsequent Supreme Court review.
The order states:
The May 22, 2025 preliminary injunction entered by the United States District Court for the District of Massachusetts … is stayed pending the disposition of the appeal in the United States Court of Appeals for the First Circuit and disposition of a petition for a writ of certiorari, if such a writ is timely sought. Should certiorari be denied, this stay shall terminate automatically. In the event certiorari is granted, the stay shall terminate upon the sending down of the judgment of this Court.
The Secretary of Education, Linda McMahon, issued a statement that included the following after the Order was issued:
Today, the Supreme Court again confirmed the obvious: the President of the United States, as the head of the Executive Branch, has the ultimate authority to make decisions about staffing levels, administrative organization, and day-to-day operations of federal agencies. While today’s ruling is a significant win for students and families, it is a shame that the highest court in the land had to step in to allow President Trump to advance the reforms Americans elected him to deliver using the authorities granted to him by the U.S. Constitution.
The U.S. Department of Education will now deliver on its mandate to restore excellence in American education. We will carry out the reduction in force to promote efficiency and accountability and to ensure resources are directed where they matter most – to students, parents, and teachers. As we return education to the states, this Administration will continue to perform all statutory duties while empowering families and teachers by reducing education bureaucracy.
Justice Sotomayor, joined by Justices Kagan and Jackson, issued a lengthy dissent, arguing the executive branch lacks the unilateral power to abolish a department created by Congress. She emphasized that the Department of Education’s statutory duties and the explicit limits Congress placed on the Secretary’s authority had been disregarded, and warned that the Court’s decision “hands the Executive the power to repeal statutes by firing all those necessary to carry them out,” posing a grave threat to the constitutional separation of powers.
Analysis of the Supreme Court’s Reasoning
While the Supreme Court’s order is procedural and does not resolve the merits of the case, its effect is to allow the executive branch to continue dismantling the Department of Education while appeals are pending. The stay does not represent a final decision on whether the President’s actions are lawful, but it does signal the Court’s willingness to permit the executive’s actions to proceed.
The dissent lays out the statutory framework: Congress established the Department of Education in 1979 and specifically limited the Secretary’s power to abolish or reorganize its offices, requiring advance notice and justification to Congress for even minor changes. The President’s action, in contrast, was a sweeping attempt to eliminate the Department without Congressional approval.
Likely Outcome for the Education Department
As a result of the Supreme Court’s stay, the Department of Education is now permitted to proceed with mass layoffs and other steps toward closure, at least until the First Circuit rules on the appeal and possibly until the Supreme Court addresses the merits. In practical terms, this means:
- Immediate Impact: The Department can continue executing the President’s order, including firing staff, eliminating offices, and transferring statutory functions to other agencies.
- Long-Term Consequences: If the appellate courts ultimately uphold the executive action, the Department of Education could be effectively dismantled, even if Congress has not formally repealed the statute creating it.
- Separation of Powers Concerns: The dissent warns that this sets a precedent for the President to nullify statutory mandates simply by firing the personnel necessary to carry them out, undermining congressional authority.
Conclusion
The Supreme Court’s decision to stay the district court’s injunction in McMahon v. New York represents a significant development in the ongoing struggle over the scope of executive power. While not a final ruling on the merits, it allows the Trump Administration to proceed with its plan to dismantle the Department of Education, despite statutory protections and congressional intent. The ultimate fate of the agency will depend on the outcome of the appellate process, but for now, the executive branch has been given a green light to continue its controversial course.
While there have been cases that have restricted actions by the administration with regard to reducing the size of the federal workforce, there have now been several Supreme Court decisions that have allowed the Trump administration to proceed with optimizing (i.e. reducing the size) of the federal workforce.
