Labor & Employment Law Daily Wrap Up, REMEDIES, DAMAGES—D.D.C.: Preliminary injunction denied in disabled plaintiffs’ case against Social Security Administration, (May 12, 2025)

By Ursula Furi-Perry, J.D.

While the plaintiffs described difficulties contacting the SSA and delays in service, they failed to show how these issues posed immediate, life-threatening consequences.

Individual and organizational plaintiffs sought a preliminary injunction against the Social Security Administration, challenging significant organizational changes at the SSA, including workforce reductions, the closure of field offices, and the dissolution of two critical administrative offices. The plaintiffs argued that these actions would severely disrupt the administration of Social Security benefits, disproportionately affecting disabled individuals who rely heavily on timely and efficient services. A District of Columbia federal district court declined to grant the preliminary injunction, holding that the individual and organizational plaintiffs failed to show immediate, irreparable harm. While the plaintiffs described difficulties contacting the SSA and delays in service, they failed to show how these issues posed immediate, life-threatening consequences (American Association of People with Disabilities. v. Dudek, No. 25-cv-00977 (APM) (D.D.C. May 6, 2025)).

The plaintiffs, consisting of several advocacy organizations—including the American Association of People with Disabilities, the National Federation of the Blind, Deaf Equality, and others—and individual disabled claimants, brought suit in federal court seeking a preliminary injunction against the Social Security Administration (SSA) and its Acting Administrator. The plaintiffs challenged significant organizational changes at the SSA, including workforce reductions, the closure of field offices, and the dissolution of two critical administrative offices: the Office of Civil Rights and Equal Opportunity (OCREO) and the Office of Transformation. They argued that these actions would severely disrupt the administration of Social Security benefits, disproportionately affecting disabled individuals who rely heavily on timely and efficient services.

Alleged harm. The plaintiffs alleged that these changes would cause irreparable harm, including delays or denials of benefits, financial hardship, increased homelessness, and food insecurity. The individual plaintiffs submitted declarations detailing personal difficulties, such as delays in applications and communications with SSA offices. The organizational plaintiffs claimed that they would have to divert resources from core advocacy work to assist affected individuals.

In discussing the procedural issue of the preliminary injunction, the court emphasized that a preliminary injunction is an extraordinary remedy, requiring the plaintiffs to establish that they will likely succeed on the merits and will likely suffer irreparable harm absent immediate relief, and that the balance of equities tips in their favor, with an injunction being in the public interest. The court underscored that the standard for irreparable harm is high; the injury must be actual, imminent, and beyond remediation.

Regarding the individual plaintiffs, the court found that none had demonstrated imminent harm directly resulting from the challenged SSA actions. Most complaints related to events predating the organizational changes or were speculative about future harm. While the plaintiffs described difficulties contacting the SSA and delays in service, they failed to show how these issues posed immediate, life-threatening consequences. The court also rejected claims of statutory and constitutional violations as unsupported and too vague to establish irreparable harm. None of the plaintiffs demonstrated that they had recently attempted to file discrimination complaints or requested accommodations directly impacted by the dissolution of OCREO or the Office of Transformation.

For the organizational plaintiffs, the court held that they likewise failed to show a “perceptible impairment” to their core activities or a direct conflict with their missions. The declarations provided lacked the specificity necessary to demonstrate actual harm resulting from the SSA’s changes. Ultimately, because the plaintiffs could not satisfy the irreparable harm requirement, the court did not analyze the remaining injunction factors. “The court shares Plaintiffs’ concerns about the effects of the challenged actions on the SSA’s capacity to deliver services, but the law requires more than what they have offered to award the extraordinary intervention of injunctive relief,” the opinion stated.

Conclusion. The federal district court denied the plaintiff’s request for a preliminary injunction.

The case is No. 25-cv-00977 (APM).

Judge: Mehta, A.

Attorneys: Anthony May (Brown, Goldstein & Levy) for American Association of People with Disabilities. Steven Chasin, U.S. Department of Justice, for Leland Dudek.

Companies: American Association of People with Disabilities

Cases: RemediesDamages Procedure DistrictofColumbiaNews