Breaking down the lawsuits challenging “Schedule Policy/Career”

As of today, three separate lawsuits have been filed to challenge President Trump’s plan to reclassify federal workers into “Schedule Policy/Career” (formerly Schedule F). Two of these suits were filed by unions representing federal employees. A third was filed by an organization that represents federal employee whistleblowers.

The suits differ on four significant dimensions: (1) The venues in which they were filed, (2) The type of injury they assert, which may determine whether a court can hear the case, (3) The specific acts they challenge, and (4) The sources of law invoked to support those challenges.

Before describing the suits, we provide some background.

Background

These lawsuits challenge two related actions the President is trying to take. The first is the creation of “Schedule Policy/Career.” The second is an effort to disregard or eliminate regulations that OPM promulgated during the Biden administration. which made it considerably more difficult to implement something like “Schedule Policy/Career.” The administration needs to take both of these steps in order to fully realize the president’s plan to strip civil service protections from thousands of federal employees.

The suits raise arguments under three sources of law: the Civil Service Reform Act, the Administrative Procedure Act, and the U.S. Constitution. We elaborate on each below.

The Civil Service Reform Act (CSRA) was enacted in 1978 and strengthened via amendments in 1990. Through this statute, Congress provided federal employees with robust job protections, such as protection against termination without cause (for most non-probationary employees). Congress also required that agencies hire most federal employees through competitive processes to ensure that employees are selected based on merit, not political loyalty to a particular party or candidate.

The statute allows the President and OPM to except employees from these requirements, only when “necessary” and as warranted by “conditions of good administration.” 5 U.S.C. § 3302.

The CSRA also provides that civil service protections may not apply to positions “determined to be of a conditional, policy-determining, policy-making or policy-advocating character.” 5 U.S.C. § 7511(b)(2). That term has long been understood to refer solely to political, non-career appointees. For example, the Merit Systems Protection Board, the entity that adjudicates many federal employee claims of wrongful termination, has held that these terms are “only a shorthand way of describing positions to be filled by so-called ‘political appointees.’” Currently, those non-career, political positions are housed in Schedule C of the excepted service.

The Administrative Procedure Act (APA) provides broad rules governing actions taken by most federal agencies. As a general matter, the APA requires agencies to engage in reasoned decision-making. When an agency wants to take an action in the form of a final rule, the APA requires the agency to use certain procedures, known as notice and comment rulemaking. The agency has to provide the public with notice of the rule it is proposing and an opportunity to comment on the rule. Then the agency must review those comments and explain why it is or is not changing its proposed rules in line with those comments.

For example, the Biden administration used notice and comment rulemaking under the APA to issue its regulations protecting civil servants. OPM issued a 24-page notice explaining the reasons for the rule and how it would operate in September 2023, received and reviewed over 4,000 comments, and then issued a 68-page notice of final rulemaking in April 2024.

When an agency wants to rescind a rule that it has promulgated using notice-and-comment rulemaking, it has to use the same process used to issue the rule—providing notice to the public, accepting comments, and analyzing those comments.

The Fifth Amendment to the U.S. Constitution provides that the government cannot deprive an individual of their property without due process of law. The Supreme Court has held that restrictions on loss of employment, like those provided to federal employees in the CSRA, can create a property right in continued employment. Constitutional due process protections then attach to that property interest.

The three lawsuits

Below we briefly describe the three lawsuits that have been filed so far:

  • NTEU v Trump (complaint here)

On the night of President Trump’s inauguration, shortly after he issued an executive order reinstating and amending the Schedule F, the National Treasury Employees Union (NTEU) filed a lawsuit challenging the order. The suit was filed in the District Court for the District of Columbia and has been assigned to Judge Cobb, a Biden appointee. This court is subject to review by the D.C. Circuit Court of Appeals, a court with seven active judges appointed by Democratic presidents and four active judges appointed by Republican president.

NTEU is a union that represents thousands of federal employees across 37 departments and agencies, including Agriculture, Commerce, Defense, Energy, and Health and Human Services, Justice, Treasury, the Interior, and Homeland Security.

NTEU filed the lawsuit on behalf of itself as an organization, not its members. NTEU asserts that it is injured as an organization because the executive order has required it to divert a significant amount of resources away from its ordinary activities.

NTEU’s complaint includes four counts. In the first count, NTEU argues that the President is violating 5 U.S.C. § 3302, which states that employees can only be place din the excepted where “necessary” or warranted by “conditions of good administration.” NTEU claims that the executive order does not meet those criteria.

In the second count, NTEU argues that the President exceeded statutory authority by attempting to strip adverse action protections from employees other than non-career, political appointees, violating the longstanding understanding that only such employees are excluded from these protections.

The third count argues that the Executive Order violates the Constitution by seeking to deprive federal employees of their constitutional due process rights in their employment.

The fourth count argues that the Executive Order violates the Administrative Procedure Act because it seeks to rescind regulations without going through the required procedures.

NTEU is requesting, as remedies, that the court declare the executive order unlawful, and enjoin the President, the OPM director, and the named agency heads from implementing, enforcing, or complying with the order.

When NTEU filed a similar suit under the first Trump administration, the Government asserted two major defenses: (1) NTEU’s claims were premature because no one had been placed into the new schedule yet, and (2) Any challenge would need to be raised through internal administrative channels rather than in court. NTEU did not have an opportunity to respond to those arguments before the Schedule F executive order was rescinded. We can expect similar defenses to be raised again now.

  • PEER v Trump (complaint here)

On January 28, 2025, Public Employees for Environmental Responsibility (PEER) filed a lawsuit in the District of Maryland. It has been assigned to Judge Xinis, an Obama appointee. This court is subject to review by the Fourth Circuit Court of Appeals, a court with eight active judges appointed by Democratic presidents, six active judges appointed by Republican presidents, and one active judge originally nominated by President Clinton and then re-nominated by President George W. Bush .

PEER is a non-profit that provides pro bono legal services to public employee whistleblowers in cases related to environmental laws and scientific integrity. PEER is asserting an injury on the basis that the executive order has significantly increased fear and concerns about retaliation by federal employees, which impedes PEER’s ability to learn about, expose, and remedy the wrongdoing that the organization exists to address.

PEER’s complaint includes four counts. The first count largely mirrors the first count of NTEU’s complaint, arguing that that the executive order violates 5 U.S.C. § 3302, because the proposed exceptions from the competitive service are neither “necessary” nor warranted by “conditions of good administration.”

PEER’s second count is similar to the third count in NTEU’s complaint, invoking the constitutional due process rights of federal employees.

The third and fourth count, like NTEU’s fourth count, challenge President Trump’s declaration that the Biden civil service regulations are now “inoperative.”

PEER is requesting that the court declare the executive order null and void and enjoin the OPM director from implementing it, and require OPM to enforce the Biden civil service regulations unless and until they are rescinded via notice and comment rulemaking.

  • AFGE v Trump (complaint here)

On January 29, 2025, AFGE and ASCME filed a lawsuit against the President, the head of OPM, and OPM. It has been assigned to Judge Cobb on the basis that it is related to the NTEU action.

AFGE is the largest federal employee union, representing approximately 800,000 federal employees in every state, including nurses, border patrol agents, scientists, civilian employees of the military, and employees who administer Social Security benefits.

AFSCME represents around 1.4 million government employees, including many federal employees—among them, employees of the FAA and DOJ.   

This lawsuit differs from the other suits in several ways.

First, the suit is brought on behalf of the unions and their members; by contrast, the NTEU suit is brought only on behalf of the union itself. This choice does not affect the substance of the claims in the case, but it does affect technical procedural defenses that the Government may raise.

Further, unlike the other lawsuits, this suit does not challenge the creation of Schedule Policy/Career or the directive to place employees into that category. Instead, it targets the administration’s attack on the Biden civil service regulations. And the lawsuit only raises claims under the Administrative Procedure Act, not the CSRA or Constitution.

The lawsuit includes two counts.

The first count argues that the OPM Director and OPM have violated the APA by holding the Biden civil service regulations “inoperative” without going through notice and comment rulemaking.

The second count argues that all defendants are acting without statutory authority by attempting to rescind the Biden civil service regulations while circumventing the requirements of the APA.

Where the suits will go from here

Notably, as of today, the plaintiffs in these lawsuits have not sought an immediate stop to the administration’s actions via a preliminary injunction or temporary restraining order. This distinguishes the lawsuits from several others filed against the Trump administration, like the challenge to the administration’s attack on birthright citizenship. The organizations may have held off on seeking immediate relief due to the perception that federal employees have not yet been directly affected by the administration’s actions (e.g., because employees have not yet been placed into Schedule Policy/Career).

Ordinarily, the United States has 60 days to respond to a complaint filed against it. Under that schedule, a response will be due in March.

Updates on the lawsuits may be posted on our Bluesky feed.

-Charlotte Schwartz and Danny Rosenthal, attorneys at James & Hoffman

What’s new in Trump’s rebranded Schedule F?

On the first day of his second term, President Trump issued an executive order reinstating the job classification formerly known as “Schedule F.” For those who have been following the Schedule F story since 2020, we thought it would be helpful to lay out what exactly has changed from the original Schedule F executive order to the new order. Please note that the executive order has already been challenged in court, and it remains to be seen whether the courts will permit the administration to move forward with anything described below.

First, the new executive order announces that the prior Schedule F executive order will be amended. We have created a document showing the amendments as a redline of the prior executive order. The new executive order does not explain the rationale for these changes, but we can make some guesses:

  • First, the new job category will be called “Schedule Policy/Career” rather than “Schedule F.” This clunky new title may be intended to make clear the Trump administration’s disagreement with OPM’s prior understanding that the excepted service is only for political appointees, not career employees.
  • Second, a paragraph regarding hiring has been removed, presumably because Trump issued a separate executive order on hiring.
  • Third, the executive order now asserts that the President will make final decisions regarding placement of employees in “Schedule Policy/Career.” In the original executive order, this task was assigned to the director of OPM. This change probably makes little difference in practice, but instead relates to technical legal arguments about the President’s authority in this area.
  • Fourth, the new executive order broadens the discretion of agencies to place employees in “Schedule Policy/Career” by including employees performing “duties that the Director otherwise indicates may be appropriate for inclusion” within the set of eligible employees. Also, employees who supervise “Schedule Policy/Career” employees may be placed into that category.
  • Fifth, the new executive order contains a paragraph announcing that “[e]mployees in or applicants for Schedule Policy/Career positions are not required to personally or politically support the current President or the policies of the current administration,” but must “faithfully implement administration policies to the best of their ability”

The original Schedule F executive order instructed agencies to conduct a preliminary review of positions within 90 days and a complete review within 210 days. Presumably, those deadlines will now run from January 20, 2025, since the new executive order indicates that January 20, 2025 will be “treated as the date of Executive Order 13957” (the original order).

Separate from reinstating and amending the original executive order, the new executive order contains a handful of other provisions. Most importantly, it instructs the OPM director to revoke regulations issued in 2024 that, among other things, prevented employees from losing job protections if involuntarily transferred to the excepted service. Recognizing that these regulations cannot be revoked immediately, the executive order asserts that the regulations will be “inoperative” in the meantime.

In addition, the executive order instructs the OPM director to “issue guidance about additional categories of positions that executive departments and agencies should consider recommending for Schedule Policy/Career.”

-Danny Rosenthal, partner at James & Hoffman, P.C.

Schedule F: What Federal Employees Need to Know

This page provides information on “Schedule F,” now known as “Schedule Policy/Career,” a new category of federal employees established near the end of the first Trump administration, rescinded by President Biden before it was implemented, and then reinstituted on the first day of President Trump’s second term.

UPDATE April 18, 2025: The administration has posted its proposed regulation implementing Schedule Policy/Career. The regulation seems to closely follow the executive order issued by President Trump on inauguration day, discussed below. We will continue reviewing the document and may post a further analysis in the coming days.

UPDATE January 29, 2025: As of today, there are three lawsuits challenging the “Schedule Policy/Career” initiative. We have published a separate post about these lawsuits. To briefly summarize, the first suit was brought by the National Treasury Employees Union in DC, where it was assigned to Judge Jia Cobb, a former civil rights lawyer appointed to the bench by President Biden. This week, two more suits were filed, one by two labor unions (AFGE and AFSCME) and another by a nonprofit. As of today, the plaintiffs in these cases have not sought an immediate injunction against the policy, perhaps because it has not yet been implemented at the agency level. The government will be required to respond to the suits in the coming months.

UPDATE January 27, 2025: OPM has issued a new memo regarding implementation of “Schedule Policy/Career.”

UPDATE January 22, 2025: On the night of his inauguration, President Trump issued an executive order reinstating Schedule F–now labeled as “Schedule Policy/Career.” It makes some amendments to the original Schedule F executive order; we discuss those changes in another post. The new executive order also directs OPM to rescind regulations issued by the Biden administration to protect civil servants from losing job protections as a result of transfer to Schedule F. Recognizing that the process of rescinding the regulations will take some time, the executive order declares that the regulations will be “inoperative” until they are formally revoked. This order creates a number of legal issues, and it remains to be seen whether the courts will permit the administration to implement its plans. A lawsuit has already been filed by the National Treasury Employees Union. More analysis will be forthcoming here and on our Bluesky account. In the meantime, scroll down for more detail on Schedule F and the OPM regulations.

This page answers the following questions:

  1. What is Schedule F?
  2. Am I in Schedule F?
  3. What is the process for transferring employes to Schedule F?
  4. If Schedule F is reinstituted, could I be placed in it?
  5. If I am placed in Schedule F, can I object?
  6. What are my rights if I am placed in Schedule F?

The information on this page is current as of January 20, 2025.

1. What is Schedule F?

To understand Schedule F, you must first understand that most federal government employees fall into two categories: competitive service and excepted service. (On your SF-50, box 34 states whether you are in one of these categories.)

Competitive service is the default category for federal government employees. See 5 U.S.C. § 2102. Employees in the competitive service have various job protections and rights, particularly after they complete their probationary period. For example, if they are terminated or suspended, these employees can appeal to the Merit Systems Protection Board (MSPB). See 5 U.S.C. §§ 7511, 7513.

The excepted service is a separate category in which hiring is not governed by competitive hiring requirements. See 5 U.S.C. § 2103. Prior to Trump’s executive order, the excepted service was divided into five categories: schedules A, B, C, D, and E. See 5 C.F.R. § 6.2.

Employees in Schedule C of the excepted service are essentially at-will employees, lacking the ability to appeal to the MSPB if they are terminated without cause. Historically, this category has been reserved for political, noncareer positions. (Unlike employees in Schedule C, employees in Schedules A, B, D, and E of the excepted service are generally protected from termination without cause.)

Schedule F, which has been renamed Schedule Policy/Career, is a new category of excepted service employees. It appears designed to strip job protections from career positions, treating them similarly to employees in Schedule C.

In an executive order in October 2020, President Trump established Schedule F. See Executive Order 13957. The order defines Schedule F to encompass: “Positions of a confidential, policy-determining, policy-making, or policy-advocating character not normally subject to change as a result of a Presidential transition.” On January 22, 2025, President Trump issued a new executive order, reinstating Executive Order 13957, with some amendments.

Prior to President Trump’s executive order, the excepted service already included positions with these characteristics in Schedule C. See, e.g., 5 C.F.R. § 6.2. However, up until now, the phrase “confidential, policy-determining, policy-making, or policy-advocating” has been understood to refer solely to non-career, political positions that would be subject to change as a result of a Presidential transition. The executive order seeks to expand that category to include career, non-political positions. Further, the order establishes a new process requiring agencies to recategorize employees into Schedule Policy/Career. Thus, the executive order appears designed to move a significant number of employees into a new category in which they lose essential job protections. We discuss this process below.

The program is currently under challenge in three different lawsuits.

2. Am I in Schedule F?

Likely not. Schedule F was reinstated on January 20, 2025 via executive order and relabeled as “Schedule Policy/Career.” However, it remains to be seen how and when agencies will actually implement the order.

3. What is the process for transferring employes to Schedule F?

Under the executive order, federal agencies are supposed to take various steps to transfer employees to Schedule Policy/Career.

First, each agency was required to conduct a “preliminary review” within 90 days and a “complete review” within 210 days, in order to identify positions that should be placed in Schedule Policy/Career.

Second, each agency was required to submit a petition to the Office of Personnel Management (OPM) identifying the positions that should be transferred to Schedule F, with a written explanation.

Third, the OPM Director will recommend to the President which positions should be placed in Schedule Policy/Career. The President intends to then effectuate the transfer of the recommended positions into Schedule Policy/Career via executive order.

In addition, OPM has directed each agency to designate a Schedule Policy/Career point of contact, and to provide that person’s contact information to OPM, by January 29, 2025.

4. If Schedule F is reinstituted, could I be placed in it?

If your position is of a “confidential, policy-determining, policy-making, or policy-advocating character,” you might fall under Schedule Policy/Career according to the executive order.

The executive order appears to give a large degree of discretion to agencies to decide which employees to place in Schedule Policy/Career. It lists various job functions that could support placing an employee in this new schedule, but it does not mandate that everyone performing these activities be placed in it.

The following job functions are listed in the executive order:

  • “substantive participation in the advocacy for or development or formulation of policy”
  • “substantive participation in the development or drafting of regulations and guidance”
  • “substantive policy-related work in an agency or agency component that primarily focuses on policy”
  • “the supervision of attorneys”
  • “substantial discretion to determine the manner in which the agency exercises functions committed to the agency by law”
  • “viewing, circulating, or otherwise working with proposed regulations, guidance, executive orders, or other non-public policy proposals or deliberations generally covered by deliberative process privilege and either directly reporting to or regularly working with an individual appointed by either the President or an agency head who is paid at a rate not less than that earned by employees at Grade 13 of the General Schedule; or working in the agency or agency component executive secretariat (or equivalent)”
  • “conducting, on the agency’s behalf, collective bargaining negotiations”
  • “directly or indirectly supervising employees in Schedule Policy/Career positions”
  • “duties that the Director otherwise indicates may be appropriate for inclusion in Schedule Policy/Career”

In a memo published on January 27, 2025, OPM listed the following as duties that would support placement in Schedule Policy/Career:

  • functions statutorily described as important policy-making or policy-determining functions, principally (1) directing the work of an organizational unit; (2) being held accountable for the success of one or more specific programs or projects; or (3) monitoring progress toward organizational goals and periodically evaluating and making appropriate adjustments to such goals
  • authority to bind the agency to a position, policy, or course of action either without higher-level review or with only limited higher-level review
  • delegated or subdelegated authority to make decisions committed by law to the discretion of the agency head
  • substantive participation and discretionary authority in agency grantmaking, such as the substantive exercise of discretion in the drafting of funding opportunity announcements, evaluation of grant applications, or recommending or selecting grant recipients
  • advocating for the policies (including future appropriations) of the agency or the administration before different governmental entities, such as by performing functions typically undertaken by an agency office of legislative affairs or intergovernmental affairs, or by presenting program resource requirements to examiners from the Office of Management and Budget in preparation of the annual President’s Budget Request
  • publicly advocating for the policies of the agency or the administration, including before the news media or on social media
  • positions described by their position descriptions as entailing policy-making, policy-determining, or policy-advocating duties.

5. If I am placed in Schedule F, can I object?

Maybe. Under regulations issued by the Biden administration in 2024, employees may have the right to file an appeal if they are involuntarily placed in the excepted service, including in Schedule F. See 5 C.F.R. § 302.603. The appeal may be filed with the Merit Systems Protection Board, or MSPB.

On January 20, 2025, the Trump Administration issued an executive order declaring that the regulations issued by the Biden administration are “inoperative.” However, it is not clear that the Trump administration has the power to render regulations “inoperative” via executive order. Several lawsuits are already pending on the issue.

For advice specific to your situation, consider consulting an attorney. If you are represented by a union, consider discussing the issue with someone from the union.

6. What are my rights if I am placed in Schedule F?

It is unclear. Under regulations issued by the Biden administration in 2024, an employee who is transferred to the excepted service, including in Schedule Policy/Career, retains many of their most important rights as a competitive service employee. These include the ability to challenge the employee’s termination and other adverse employment actions. See 5 C.F.R. § 212.401; 5 C.F.R. § 302.602(c).

On January 20, 2025, the Trump Administration issued an executive order declaring that the regulations issued by the Biden administration are “inoperative.” However, it is not clear that the Trump administration has the power to render regulations “inoperative” via executive order. Several lawsuits are already pending on the issue.

Further, there is case law suggesting that federal employees have this protection even in the absence of the recent regulation.

Notably, OPM’s January 27 memo suggests that the Trump administration considers 5 C.F.R. § 212.401 to still be operative, thus protecting employees from loss of civil service protections if transferred to Schedule Policy/Career. This regulation has existed since 1968. In 2024, OPM amended it to clarify that it would apply to involuntary movement to any newly created schedule in the excepted service.

Thus a federal employee who is transferred to Schedule Policy/Career may still have protections from unwarranted termination and other adverse employment actions. By contrast, if you are hired directly into a Schedule Policy/Career position or choose to take one voluntarily, then you likely will have limited rights to challenge termination or other adverse action. However, if you are coerced into accepting a Schedule F position, then you may be able to appeal the agency’s action. See 5 C.F.R. § 302.602.

For advice specific to your situation, consider consulting an attorney. If you are represented by a union, consider discussing the issue with someone from the union.

-Danny Rosenthal and Charlotte Schwartz, attorneys at James & Hoffman, P.C.,