Federal Government Appeals Preliminary Injunctions in PRWORA Litigation
The federal government has filed appeals of two preliminary injunctions blocking enforcement of the July 2025 PRWORA reinterpretation—one in the First Circuit covering 20 plaintiff states and D.C., and one in the Ninth Circuit covering Head Start programs nationwide. Both injunctions remain in place while the appeals are pending, meaning current enforcement restrictions continue for affected states and Head Start grantees.
Uncertainties for Employers and Borrowers under Department of Education’s New Public Service Loan Forgiveness Regulation
A final PSLF regulation published October 31, 2025 adds exclusions from "qualified employer" status for organizations the Secretary determines have a "substantial illegal purpose"—with a definition broad enough to encompass work related to immigration services, gender-affirming care, student protests, and DEI initiatives. The rule gives the Secretary discretionary authority to disqualify employers with narrow appeal rights and a 10-year bar on reapplication, immediately ceasing loan payment credits for employees of disqualified organizations, and is already subject to two separate legal challenges before it takes effect July 1, 2026.
U.S. Department of Education Reductions in Force (RIFs)
The new Continuing Resolution has paused all federal agency RIFs government-wide and requires reinstatement, with back pay, for employees separated during the shutdown period. All RIF actions taken between October 1 and November 12, 2025 are invalid, and no agency may initiate or implement a RIF through January 30, 2026.
Press Release
Former U.S. Department of Education attorneys Emily Merolli, Jill Siegelbaum, and Josie Eskow Skinner have launched Sligo Law Group, PLLC, a boutique federal education law firm designed to fill the expertise gap created by sweeping layoffs at the Department's Office of General Counsel. The firm advises K–12 agencies, higher education institutions, nonprofits, and advocacy organizations on federal education law, grants compliance, civil rights, and employment matters.
The One Big Beautiful Bill Act: What Does it Mean for Education?
On July 4, 2025, the President signed H.R. 1—the "One Big Beautiful Bill Act"—into law, enacting sweeping changes across nearly every area of domestic federal policy, including K–12 and higher education. Sligo Law Group has prepared a breakdown of the Act's most consequential education provisions for organizations working to understand and navigate its impacts.
Trump Administration Announces Significant Changes to Eligibility for Head Start, Adult Education, Career and Technical Education Programs, Among Others
On July 10, 2025, the Departments of Education and Health and Human Services announced new legal interpretations that reverse over 20 years of guidance, classifying adult education, postsecondary CTE, and a broad array of HHS programs—including Head Start—as "federal public benefits" subject to PRWORA immigration-status eligibility and verification requirements. ED's interpretive rule explicitly states that Plyler v. Doe does not extend to adult or postsecondary education programs, with immediate operational implications for grantees under WIOA Title II and the Perkins Act.
Supreme Court Decision in Mahmoud v. Taylor Raises New Questions for Schools and Educational Agencies
In a 6–3 decision, the Supreme Court ruled that a Maryland school district's refusal to allow religious families to opt their children out of LGBTQ+-inclusive curriculum materials substantially burdened their free exercise rights and triggered strict constitutional scrutiny—a meaningful departure from the longstanding Employment Division v. Smith framework. The decision raises the legal bar for school policies that incidentally burden religious beliefs, even neutral and generally applicable ones, and increases litigation exposure for districts and educational agencies that deny religious accommodation requests.