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Updated September 3, 2025, at 11:45 p.m.
A federal judge ruled that the Trump administration violated the Constitution when it froze more than $2.6 billion in research funding to Harvard, striking down the freeze in its entirety and delivering the University a major legal victory.
The decision from United States District Judge Allison D. Burroughs hands Harvard a summary judgment win on core constitutional grounds, finding that the administration’s freeze orders were retaliation for protected speech. She also found that the government failed to comply with Title VI of the 1964 Civil Rights Act, which requires agencies to give notice, investigation, and an opportunity to respond before terminating federal financial assistance over civil rights violations.
Burroughs’ order vacated both the freeze orders and termination notices that Harvard received in the days after it rejected sweeping demands from the Trump administration this April as violations of the First Amendment. She also handed Harvard a permanent injunction that prevents the Trump administration from reimposing unconstitutional conditions on its funding.
“A review of the administrative record makes it difficult to conclude anything other than that Defendants used antisemitism as a smokescreen for a targeted, ideologically-motivated assault on this country’s premier universities,” she wrote in her order.
The standoff between Harvard and the Trump administration began in late March, when federal agencies sent the University a letter conditioning billions of dollars in multiyear grant commitments on a set of preconditions. In April, the administration broadened its demands — asking Harvard to restructure its governance, hiring, and disciplinary processes, subject to audits by the government.
When Harvard rejected the conditions, the Trump administration responded just hours later by cutting $2.2 billion in federal funding, then turned up the pressure by pulling hundreds of millions more. Harvard responded by suing nearly a dozen federal agencies and their leaders, saying the repeated cuts were retaliatory measures intended to punish the University for exercising its First Amendment rights.
In her order on Wednesday, Burroughs slammed the government’s conditions and argued that they had little to do with combating antisemitism — the administration’s stated justification — and “everything to do with Defendants’ power and political views.”
Burroughs also ruled that the freeze orders were “arbitrary and capricious” under the Administrative Procedure Act, stating that federal agencies had gathered virtually no evidence about antisemitism at Harvard prior to issuing them. She noted that the primary document used by the White House to argue that Harvard had let antisemitism run rampant — a report by an internal University task force — was published two weeks after the April 14 freeze.
White House spokesperson Liz Huston condemned the decision — targeting Burroughs, an Obama appointee, and alleging she had ruled without fully considering the facts — and confirmed that the administration plans to appeal.
“We will immediately move to appeal this egregious decision, and we are confident we will ultimately prevail in our efforts to hold Harvard accountable,” she wrote.
Trump has previously vowed on social media to “IMMEDIATELY appeal, and WIN” if Burroughs ruled against him, raising the prospect of a drawn-out, multi-year legal battle that could ultimately end before a Supreme Court that may have little sympathy for Harvard.
In the meantime, absent intervention from an appeals court, agencies are required to resume ordinary processing of funds that were halted by the freezes this spring.
The decision is a landmark victory for Harvard in its monthslong legal standoff against the Trump administration. But it also comes as Harvard quietly continues negotiation talks with the White House. In recent weeks, Harvard had reportedly agreed to commit $500 million toward workforce development initiatives in exchange for winning back the $2.7 billion in frozen grants and contracts.
But Burroughs’ ruling already restores the funding, potentially giving Harvard additional leverage in its talks with the White House. The order — and Harvard’s federal funding lawsuit — do not address the barrage of other actions that the Trump administration has slung at Harvard, including a string of investigations and repeated attempts to prevent its international students from studying in the U.S.
In an email to Harvard affiliates hours after the ruling, University President Alan M. Garber ’76 praised the court’s decision as a defense of higher education’s core principles.
“This important decision affirms our First Amendment and procedural rights, upholds the principles of academic freedom, and validates our arguments in defense of critical scientific research and the core values of American higher education,” Garber wrote.
But Garber acknowledged continued uncertainty around the fate of Harvard’s federal funding, writing that the University “will continue to assess the implications of the opinion, monitor further legal developments, and be mindful of the changing landscape in which we seek to fulfill our mission.”
The highly anticipated ruling followed requests from both Harvard and the federal government to settle the case through summary judgment, which allows a judge to decide based on the record rather than a full trial. Harvard had asked Burroughs to rule before a Sept. 3 federal deadline, after which the Trump administration could have argued it was impossible to restore the slashed funds. She issued her order with less than a day remaining.
Over the summer, the White House submitted more than 2,000 pages of documents relating to the freeze in an effort to justify the timing, and necessity, of the cuts. Shortly after, Burroughs heard arguments from lawyers for both Harvard and the Trump administration in a packed hearing in a Boston courtroom.
At that hearing, she signaled skepticism of the government’s case, pressing Justice Department lawyer Michael K. Velchik ’12 to explain how cutting billions in research funding advanced the White House’s stated goal of combatting antisemitism. At one point, she called the White House’s rationale “a little bit mind-boggling.”
But Burroughs’ Wednesday ruling did not spare Harvard from criticism. Burroughs — who is Jewish — wrote that she believes Harvard responded only belatedly to antisemitic discrimination.
“It is clear, even based solely on Harvard’s own admissions, that Harvard has been plagued by antisemitism in recent years and could (and should) have done a better job of dealing with the issue,” she wrote — but added there was “little connection between the research affected by the grant terminations and antisemitism.”
And she objected to the idea that First Amendment rights should be curbed in the interest of fighting antisemitism.
“It is important to recognize and remember that if speech can be curtailed in the name of the Jewish people today, then just as easily the speech of the Jews (and anyone else) can be curtailed when the political winds change direction,” she wrote.
Burroughs was assigned to the funding case after Harvard’s attorneys argued it was related to an earlier lawsuit brought by the University’s chapter of the American Association of University Professors, which also challenged the funding review.
She proved to be a favorable draw for Harvard: over the past decade on the bench, Burroughs, an Obama appointee, has overseen several high-profile cases involving the University. Most notably, she sided with Harvard in a 2019 challenge to its race-conscious admissions policy — a decision later overturned by the Supreme Court in 2023.
The Trump administration tried to shift the case out of Burroughs’ hands to the Court of Federal Claims, whose 16-member bench has 10 Trump appointees. Burroughs largely rejected the maneuver, saying that Harvard’s First Amendment and Title VI arguments could not be appropriately resolved in federal claims court, though she agreed that she could not hear certain of Harvard’s APA claims.
—Staff writer Dhruv T. Patel can be reached at dhruv.patel@thecrimson.com. Follow him on X @dhruvtkpatel.
—Staff writer Avani B. Rai can be reached at avani.rai@thecrimson.com. Follow her on X @avaniiiirai.
—Staff writer Saketh Sundar can be reached at saketh.sundar@thecrimson.com. Follow him on X @saketh_sundar.
