The Supreme Court handed the Trump administration a sweeping victory on July 14, 2025, in McMahon v. New York, No. 24A1203. In a 6-3 per curiam order, the Court stayed a District of Massachusetts preliminary injunction and cleared the way for the administration’s reduction in force of approximately 1,378 Department of Education employees to proceed. My read: this is a landmark moment for the separation of powers and for anyone who believes the executive branch should actually be run by the elected executive.
What the Court Did — and Didn’t Do
The order is shadow-docket, which means there is no full majority opinion — just the grant of the stay. The Court’s language was direct:
The application for stay presented to Justice Jackson and by her referred to the Court is granted. The May 22, 2025 preliminary injunction entered by the United States District Court for the District of Massachusetts is stayed pending the disposition of the appeal to the United States Court of Appeals for the First Circuit and disposition of a petition for a writ of certiorari, if such a writ is timely sought.
That single paragraph ended months of lower-court obstruction. Judge Myong J. Joun of the District of Massachusetts had issued the injunction on May 22, 2025, halting the RIF. The First Circuit, under Chief Judge David Barron, refused to stay that injunction on June 4, 2025. So the case came to the Supreme Court — and all six conservative justices said enough.
To be clear: the stay is not a merits ruling. The Court has not declared the RIF lawful in a final sense. What it has said is that the government is likely to prevail and that the harm from keeping the injunction in place outweighs the harm from lifting it. That is a significant signal.
The Dissent Tells You Everything You Need to Know
Justice Sotomayor authored a 19-page dissent, joined by Justices Kagan and Ketanji Brown Jackson. She wrote:
This case arises out of the president’s unilateral efforts to eliminate a cabinet level agency established by Congress nearly half a century ago, the Department of Education. As Congress mandated, the department plays a vital role in this nation’s education system, safeguarding equal access to learning and channeling billions of dollars to schools and students across the country each year. Only Congress has the power to abolish the department.
That framing is worth examining closely. The dissent is not wrong that Congress created the Department of Education — that happened via P.L. 96-88 in 1979. But the question before the Court is not whether Congress can create executive agencies. It unquestionably can. The question is whether Congress can then use that power to strip the President of his Article II authority to manage the workforce of those agencies. That is a very different question, and the majority’s stay suggests the six justices in the majority do not think the district court got that balance right.
Article II Is Not Optional
The deeper principle here is straightforward. Article II vests all executive power in a single President. The Department of Education is an executive agency. Its employees serve in the executive branch. When the President directs his Secretary of Education to restructure that workforce, he is exercising core executive authority — the same authority every president since Washington has used to manage his own branch.
The dissenters want to treat this as Congress’s turf because Congress created the agency. But that reasoning would hollow out the unitary executive entirely. Under that logic, every time Congress appropriates money for a program, it acquires a veto over how the executive manages the people who administer it. That cannot be right. Imagine Congress telling the Chief Justice how to staff his chambers — nobody would accept that, and for good reason. The same logic applies here, running the other direction.
Secretary Linda McMahon was appointed precisely to do this work. President Trump told her as much: he wanted her to put herself out of a job. A 1,378-employee RIF, roughly half the department’s workforce, is the first concrete step on that path.
The Pattern at the Lower Courts
This is not an isolated incident. Over and over, district judges in Boston and elsewhere have issued sweeping injunctions against Trump administration policies, and over and over the Supreme Court has stepped in to restore order. The First Circuit’s denial of the government’s stay request on June 4 is part of that same pattern — lower-court resistance that ultimately had to be corrected from above.
I have been arguing for months that the real fight over the administrative state is playing out one emergency application at a time, and this ruling confirms it. The trend at the Supreme Court is unmistakable: the majority is not willing to let district court judges run the executive branch by injunction.
Why This Matters Beyond Education
My audience follows Second Amendment cases closely, and I want to be direct about why McMahon v. New York belongs in that conversation even though it has nothing to do with guns. The same unelected bureaucratic apparatus that churns out anti-gun regulations is housed throughout the executive branch. When the Supreme Court affirms that the President has Article II authority to restructure and reduce that apparatus, it strengthens the executive’s hand across the board — including in agencies that have made gun owners their target for decades.
Dismantling one piece of the administrative state sends a message to all the others. The history of the future has yet to be written, but the Court just handed the pen back to the right branch of government.
This article is based on analysis by Professor Mark W. Smith, constitutional attorney and Host of the Four Boxes Diner 2nd Amendment channel. Watch the original video here. This does not constitute legal advice.