On April 10, 2026, the United States Department of Justice (“DOJ”) announced the first False Claims Act resolution secured under the Civil Rights Fraud Initiative with International Business Machines Corporation (“IBM”). We have previously reported on the Civil Rights Fraud Initiative, which was initiated in May 2025. The initiative is a coordinated enforcement effort
On March 26, 2026, the President issued Executive Order 14398, “Addressing DEI Discrimination by Federal Contractors” (the “Order” or “EO 14398”). The Order buttresses Executive Order 14173, “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” (“EO 14173”) issued on January 21, 2025, which we have previously reported on. EO 14173 revoked the longstanding affirmative
The Department of Justice recently released a memorandum titled “Guidance for Recipients of Federal Funding Regarding Unlawful Discrimination.” In this blog post, Hahn Loeser attorneys Matthew Wagner, J. Patrick White, and Matthew Grashoff analyze that memorandum, discuss what it does—and doesn’t—say about what may constitute “unlawful discrimination,” and provide key takeaways for federal
On June 9, 2025, the U.S. District Court for the Northern District of California issued a preliminary injunction in San Francisco A.I.D.S. Foundation, et. al. v. Trump, 25-cv-01824-JST (N.D. Cal.), enjoining three of the nine provisions of Executive Orders 14151, 14173, and 14168. Specifically, the Court enjoined the named defendants from enforcing (1) the
The U.S. Department of Justice (DOJ) launched the Civil Rights Fraud Initiative (the “Initiative”), which was announced on May 19, 2025 via Memorandum from Deputy Attorney General, Todd Blanche, and a related press release (the “Memorandum”). The Initiative is a coordinated enforcement effort by various DOJ components and other federal agencies to investigate and prosecute
We recently wrote about the preliminary injunction entered by the U.S. District Court for the Northern District of Illinois, blocking the Department of Labor from enforcing certain provisions of Executive Orders 14173 and 14151, both of which limit or prohibit federal grants or programs relating to “illegal,” “unlawful,” and “immoral” diversity, equity, and inclusion (“DEI”).
On April 23, 2025, the United States Department of Justice announced that it is rescinding the January 31, 2022 Notice of Report on Lawful Uses of Race or Sex in Federal Contracting Programs (the “2022 Report”). The April 23 announcement (the “Announcement”) does not clarify what practices or activities constitute inappropriate DEI programs. Rather, the
On April 2, we reported that Judge Matthew Kennelly of the U.S. District Court for the Northern District of Illinois had issued a temporary restraining order blocking the Department of Labor from enforcing certain provisions of Executive Orders 14173 and 14151, both of which limit or prohibit federal grants or programs relating to “illegal,” “unlawful,”
On March 27, 2025, Judge Matthew Kennelly of the U.S. District Court for the Northern District of Illinois issued a temporary restraining order blocking the Department of Labor from enforcing certain provisions of Executive Orders 14173 and 14151, both of which limited or prohibited federal grants or programs relating to “illegal,” “unlawful,” and “immoral”
On March 14, 2025, The U.S. Court of Appeals for the Fourth Circuit granted the government’s request to stay a nationwide preliminary injunction that blocked enforcement of elements of President Trump’s Executive Order 14173 (signed January 21, 2025) ending DEI programs within federal grant and contract processes, and his similar Executive Order 14151 (signed January