National Job Corps Association v. Department of Labor (Job Corps Appeal 2025)

The Department of Labor's decision to close most Job Corps centers without following WIOA's required procedures for program changes directly implicates the rule that agency action terminating congressionally created programs must comply with statutory procedures and is subject to APA review. The government's invocation of cost and performance concerns, without the reasoned explanation and procedural compliance required by WIOA, appears insufficient under the arbitrary-and-capricious standard a deficiency reflected in the district court's grant of a preliminary injunction based on likelihood of success on the merits. The statutory framework for Job Corps, as a congressionally created and funded program, likely also engages the major questions doctrine, which requires clear authorization for termination or substantial curtailment of such programs. The appellate court now considers whether the district court correctly applied these doctrines to find that the administration's unilateral closure violates both APA requirements and the bounds of executive authority.