The document is an unopposed motion and proposed amicus curiae brief submitted to the U.S. District Court for the District of Massachusetts by major national associations representing leading academic and research institutions. These organizations—including the Association of American Medical Colleges, the American Council on Education, and others—seek leave to file a brief supporting the plaintiffs' motion for a preliminary injunction in a case challenging actions by federal health agencies and officials. The amici argue that recent mass terminations of National Institutes of Health (NIH) research grants, purportedly on the basis of new policy priorities instituted by the current administration, are both unauthorized under existing law and regulation and arbitrary and capricious under the Administrative Procedure Act.
The brief emphasizes the vital importance of stable, predictable, and reliable NIH funding, undergirded by publicly announced multi-year strategic priorities as mandated by Congress. It contends that NIH’s abrupt reversals and terminations threaten the integrity of the American biomedical research enterprise, create substantial and unaddressed reliance interests for institutions, researchers, students, and research participants, and undermine the research infrastructure built upon longstanding expectations of good-faith governmental partnership. The amici assert that neither the cited Office of Management and Budget (OMB) guidance nor current regulatory frameworks permit NIH’s sweeping discretionary terminations, especially absent clear cause or opportunity for corrective action. The brief further argues that the terminations reflect an unreasoned policy change, lack adequate explanation, fail to consider significant reliance interests, do not explore reasonable alternatives, and contradict both statutory intent and fairness. Ultimately, the amici urge the court to grant preliminary injunctive relief to prevent lasting damage to the nation’s research capacity and the public interest.
