Labor & Employment Law Daily Wrap Up, GOVERNMENT CONTRACTS—D.D.C.: Federal district court stays DOL’s shuttering of 99 private Job Corps centers, (Jul 30, 2025)

By Jason Albright, J.D.

DOL did not publish its directive in the Federal Register, establish a comment period, or inform Congress of its decision.

A federal district court in D.C. has issued a preliminary injunction and stay under the Administrative Procedure Act against the Department of Labor’s closure of 99 Job Corps residential training centers operated by private entities under DOL contracts throughout the country. In a case brought by seven Job Corps enrollees, the court found that the Workforce Innovation and Opportunity Act requires DOL to engage in certain procedures—including notice and comment—before closing any Job Corps center, and that the closures, which suspended operations at all the centers at issue without any expectation of future reopening, constituted “closures” under the WIOA. Further, DOL’s asserted harms from an injunction—continuing to spend funds appropriated by Congress for a program the agency believes does not accord with government priorities—were outweighed by the loss of housing, educational and vocational opportunities, and healthcare services that the enrollees would suffer in the absence of an injunction (Cabrera v. U.S. Department of Labor, No. 25-cv-1909 (DLF) (D.D.C. July 25, 2025)).

Job Corps. The Job Corps is a national program designed to “assist eligible youth to connect to the labor force by providing them with intensive social, academic, career and technical education, and service-learning opportunities, in primarily residential centers, in order for such youth to obtain secondary school diplomas or recognized postsecondary credentials.”

Workforce Innovation and Opportunity Act. Under the Workforce Innovation and Opportunity Act (WIOA), the Department of Labor (DOL) is required to enter into agreements “for the operation of each Job Corps center.” 29 U.S.C. § 3197(a)(1)(A). DOL also enters into agreements with the Department of Agriculture to operate Civilian Conservation Centers in primarily rural areas. 29 U.S.C. § 3197(d)(1). There are currently 123 Job Corps centers nationwide. Ninety-nine of them are operated by private entities under contracts with DOL, and 24 Civil Conservation Centers are operated by the Department of Agriculture pursuant to an inter-agency agreement. This case concerns the 99 centers operated by private entities.

Procedural requirements of WIOA. Under the WIOA, DOL must comply with certain procedural requirements “[p]rior to the closure of any Job Corps center.” 29 U.S.C. § 3209(j). As specified in the statute, DOL must publicly announce the proposed decision to close any center through a publication in the Federal Register; undertake a “reasonable comment period”; and notify “the Member of Congress who represents the district” encompassing the center “within a reasonable period of time in advance of any final decision to close the center.”

In addition, the WIOA requires DOL to “establish written criteria” that it “shall use to determine when a Job Corps center supported under this part is to be closed.” 29 U.S.C. § 3211(c).

May 29 DOL directive. On May 29, 2025, DOL leadership issued a directive “announcing that performance under the operations contracts at the 99 contractor-operated Job Corps Centers should be terminated immediately with all shutdown activities to be completed no later than June 30, 2025.” Following the directive, DOL issued notices of termination or nonrenewal to each Job Corps contractor. The notices instructed contractors to “commence immediately an orderly shutdown of operations” at their Job Corps centers “[i]n anticipation of the cessation of operations... after June 30th.” The notices also instructed center operators to promptly separate students from the Job Corps program and to ensure that there be “no expectation of transfer to another center or return to their current center.”

No publication in Federal Register. DOL did not publish its directive in the Federal Register, establish a comment period, or inform Congress of its decision, despite those specific statutory requirements.

DOL press release. Also on May 29, DOL issued a press release announcing “a phased pause in contractor-operated Job Corps centers nationwide” to “occur by June 30, 2025. The release stated that the Job Corps program was being shut down because it was experiencing “significant financial challenges under its current operating structure” and was “no longer achieving the intended outcomes that students deserve.” Th press release also noted that the shutdown “decision aligns with the President’s FY 2026 budget proposal.”

Shutdown process. Following DOL’s issuance of the termination and non-renewal notices, all 99 privately operated Job Corps centers began to shut down. Students were informed that they were to promptly depart the affected centers and find alternative housing.

Disruptions for students. The shutdowns disrupted students’ studies and vocational training and restricted their access to services previously provided by Job Corps centers.

Enrollees’ lawsuit. Thereafter, on June 18, 2025, seven student-enrollees in the Job Corps program filed this suit on behalf of themselves and a putative class of student-enrollees at all 99 affected centers. They challenged DOL’s “closure of the 99 Job Corps centers and indefinite suspension of the Job Corps program” as arbitrary and capricious and not in accordance with law, in excess of statutory authority, and implemented without observance of procedure required by law, all in violation of the Administrative Procedure Act (APA), 5 U.S.C. § 706.

The enrollees sought a preliminary injunction “order[ing] the reopening of all 99 Job Corps centers and the resumption of Job Corps program operations nationwide” or a stay of DOL’s actions under the APA, specifically 5 U.S.C. § 705.

Jurisdiction. The federal district court first found that it had jurisdiction under WIOA’s statutory scheme, rather than the Tucker Act, which would confer exclusive jurisdiction on the Court of Federal Claims. The plaintiffs asserted that DOL violated statutory mandates by failing to comply with WIOA’s procedural requirements, and they did not allege that DOL breached any contract. Thus, the plaintiffs’ asserted rights existed independently of any contract between DOL and the Job Corps center operators that might implicate the Tucker Act.

Standing. The enrollees also had standing to bring their claims because they alleged injuries—“loss of training, vocational services, housing, and health services”—stemming from the shutdown of the Job Corps centers. These injuries were both directly traceable to the challenged action—DOL’s allegedly unlawful closure of Job Corps centers—and redressable by injunctive relief setting aside that agency action.

Required procedures. Turning to the APA claims, the court observed that the WIOA requires DOL to engage in certain procedures—including a period of notice and comment—before closing any Job Corps center. See 29 U.S.C. §§ 3209(j), 3211(c). And DOL failed to comply with these statutory requirements. Thus, the success of the enrollees’ APA claims “largely turns on whether the shutdowns constituted ‘closures’ under the WIOA.

“Closures” under the WIOA and likelihood of success. Observing that the WIOA does not define what it means to “close” a Job Corps center, the court noted that the term “close” means “to suspend or stop the operations of” something, Merriam Webster’s Collegiate Dictionary (11th ed. 2003), or “to conclude” or “bring to an end,” Black’s Law Dictionary (12th ed. 2024). Here, DOL issued termination and non-renewal notices directing each privately operated Job Corps center to immediately cease all work except that “necessary to provide a safe, orderly and prompt shutdown of center operations.” That, the court observed, “plainly falls under the ordinary meaning of closure.”

DOL’s nationwide shutdown, moreover, was not only unprecedented, but also inconsistent with its historic “standard of practice.” Earlier “pauses” had left open a realistic possibility that Job Corps center operations would be resumed. Here, in contrast, DOL’s notices of termination and non-renewal instructed Job Corps center operators to inform departing students that “[t]here should be no expectation of transfer to another center or return to their current center.”

In short, the court found, because DOL unlawfully “closed” all 99 privately operated Job Corps centers, in violation of the WIOA, that the plaintiffs had established a likelihood of success on the merits of their APA claims.

Irreparable harm. They also established irreparable harm. As a result of DOL’s decision to close all 99 of its privately operated Job Corp centers, the court noted, student-enrollees have lost or soon will lose access to essential services. Some have already lost housing and healthcare. Others have lost vocational and educational opportunities. And still others expect to become homeless if their centers close. Courts routinely find such harms irreparable, and “[t]he certainty and imminence of such harms are all the greater in cases involving at-risk individuals, as here.”

Balance of harms and public interest. Finally, the balance of harms and public interest, which “merge when the Government is the opposing party,” favored an injunction. DOL argued that it will be harmed by an injunction because it will have to continue to spend funds appropriated by Congress for a program that it believes does not accord with government priorities and fails to “produce good value and outcomes for program participants and others,” but the government “cannot suffer harm from an injunction that merely ends an unlawful practice or reads a statute as required to avoid constitutional concerns,” the court observed. These asserted harms were “outweighed by the loss of housing, educational and vocational opportunities, and healthcare services that plaintiffs would suffer in the absence of an injunction.” And finally, “[t]he public interest is served when administrative agencies comply with their obligations under the APA.”

Scope of relief under APA. Turning to the scope of relief under the APA, the court opted for a nationwide stay applicable to all 99 privately operated Job Corps centers throughout the country. DOL argued that any relief under the APA should be limited to the parties before the court, but a stay under 5 U.S.C. § 705 is not a party-specific remedy. That section of the APA specifies “what courts are authorized to do with respect to agency actions, not parties,” and it specifically authorizes a federal district court to “issue all necessary and appropriate process to postpone the effective date of an agency action or to preserve status or rights.” Further, pre-APA cases also “confirm that an interim form of vacatur was understood by both courts and Congress to be the ordinary preliminary remedy in a challenge to an unlawful agency action. See, e.g., Scripps-Howard Radio, Inc. v. FCC, 316 U.S. 4, 9—10 (1942); cf. Corner Post, 603 U.S. at 840 (Kavanaugh, J., concurring) (discussing pre-APA statutes authorizing courts to set aside agency actions).”

In short, concluded the court, because the plaintiffs showed that each of the four preliminary injunction factors weighed in their favor, they were entitled to a stay of DOL’s directive to close all 99 privately operated Job Corps centers.

The case is No. 25-cv-1909 (DLF).

Judge: Dabney, F.

Attorneys: Aaron Fleisher (Southern Poverty Law Center) for Anaria Cabrera, Deondre Burkes, Maddex Davis-Newman, Athena Sasser, Logan Christensen, Abigail Shauger. C.D. Zareen Iqbal, U.S. Department of Justice, for U.S. Department of Labor and Lori Chavez-Deremer.

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