1st Circuit Scorecard: How the Trump Administration Is Faring Before the Appellate Courts

Unfortunately, the same cannot be said of its luck with the Circuit Courts of Appeals (although, of course, the success rate varies somewhat among the different circuits). We'll go through them in order, starting with the 1st Circuit, which includes Maine, Massachusetts, New Hampshire, Rhode Island, and Puerto Rico. 

SEE: SCOTUS Scorecard: How the Trump Administration Is Faring Before the High Court (So Far)

Explanatory Notes

First, though, some caveats/clarifications: 

• This list may not be comprehensive — it's possible I've missed a stray case here or there, though I've done my best to keep up with them all, particularly at the appellate level.
• These rulings are largely procedural in nature, rather than on the merits.
• In some instances, the same case has gone before the 1st Circuit more than once — each of the court's rulings is counted separately.
• In other instances, two or more cases may have been consolidated on appeal — a ruling is counted once for each case, even if they're included in the same opinion/order.
• Some of these cases have already made at least one trip to the Supreme Court, but the tallies below are based purely on how the 1st Circuit has ruled. 
• While I grouped the SCOTUS cases by subject matter, these are arranged chronologically (based on when the initial lawsuit was filed).
• The same  ✅, ❌, and ↔️ signifiers will be used to indicate a "win," "loss," or "draw" for the administration. 

Lastly, because folks almost always inquire: The five sitting active judges in the 1st Circuit are all Democrat appointees (one Obama, four Biden). There are several senior judges, as well, but only two, William Kayatta (also appointed by Obama) and Jeffrey Howard (appointed by George W. Bush), have participated in any of the decisions noted below. (There is a Trump nominee, Joseph Dunlap, awaiting confirmation, for what it's worth.)

So, what's the score in the 1st Circuit? 

The Scorecard

1. NH Indonesian Community Support v. Trump — (birthright citizenship) — New Hampshire District Court Judge Joseph LaPlante granted the plaintiffs' motion for preliminary injunction. The administration appealed. The 1st Circuit affirmed the district court on October 3, 2025.

Score: ❌ Administration - 0; Challengers - 1

2. O. Doe, et al. v. Trump — (birthright citizenship) — Massachusetts District Court Judge Leo Sorokin granted the plaintiffs' motion for preliminary injunction. The administration appealed. The 1st Circuit affirmed the district court on October 3, 2025.

Score: ❌ Administration - 0; Challengers - 2

3. State of New Jersey v. Trump — (birthright citizenship) — This one's a two-parter: 1) Massachusetts District Court Judge Leo Sorokin granted the plaintiffs' motion for preliminary injunction. The administration appealed. The 1st Circuit denied the administration's motion for stay pending appeal on March 11, 2025. The case went up to the Supreme Court, which granted a partial application for stay and issued an opinion regarding the proper scope of injunctions. 2) Sorokin later assessed the scope of his previously issued injunction in light of the Supreme Court opinion and determined that there was "no workable, narrower alternative to the injunction issued originally." The administration appealed that order and the 1st Circuit affirmed the district court on October 3, 2025.

1. Score: ❌ Administration - 0; Challengers - 3
2. Score: ❌ Administration - 0; Challengers - 4

4. State of New York v. Trump — (OMB memo temporarily pausing grants, loans, assistance) — This one's a three-parter: 1) Rhode Island District Court Judge John McConnell Jr. granted the plaintiffs' motion for a temporary restraining order (TRO). The administration appealed, but then dismissed that appeal. 2) McConnell subsequently granted the plaintiffs' motion for preliminary injunction. The administration appealed. The 1st Circuit denied the administration's motion for a stay pending appeal. 3) McConnell subsequently granted the plaintiffs' motion to enforce the preliminary injunction, which the administration again appealed. That appeal has now been consolidated with the second one, and those are set for oral argument on November 18, 2025.

Three scores to tally here: 

1. Score: ↔️ Administration - 0; Challengers - 4
2. Score: ❌ Administration - 0; Challengers - 5
3. Score: ↔️ Administration - 0; Challengers - 5

5. American Federation of Government Employees, AFL-CIO v. Ezell — (OPM "Fork Directive"/deferred resignation offer to federal employees) — Massachusetts District Court Judge George O'Toole Jr. denied the plaintiffs' motion for preliminary injunction and subsequently dismissed their amended complaint (a rare win at the district court level for the administration). The plaintiffs appealed that dismissal just recently (on October 7), so no decision on that yet. 

Score: ↔️ Administration - 0; Challengers - 5

6. Orr v. Trump — (transgender passport policy) — Massachusetts District Court Judge Julie Kobick granted (in part) the plaintiffs' motion for a preliminary injunction and subsequently granted class certification. The administration appealed. The 1st Circuit denied the administration's motion for a stay pending appeal on September 4, 2025.

Score: ❌ Administration - 0; Challengers - 6

7. Commonwealth of Massachusetts v. NIH/Association of American Universities v. HHS/Association of American Medical Colleges v. NIH — (NIH guidance re: reduction of indirect cost reimbursement rate for research institutions) — This is actually a trio of related cases in which Massachusetts District Court Judge Mary Page Kelley entered judgment in favor of the plaintiffs and issued a permanent injunction in April. The administration appealed, and the cases are consolidated on appeal. The cases are still in the briefing stage with no oral argument date set yet, so no decision has been made. (Since that's a draw as to all three, I'm just noting the score here once.)

Score: ↔️ Administration - 0; Challengers - 6

8. Massachusetts Fair Housing Center v. HUD — (denial of federal grants) — Massachusetts District Court Judge Richard Stearns initially granted the plaintiffs' motion for a TRO, then granted the administration's motion to dissolve it. The plaintiffs appealed the order dissolving the TRO. The case was argued before the 1st Circuit on July 30, 2025, but they have not yet ruled on it. 

Score: ↔️ Administration - 0; Challengers - 6

9. Doe v. Noem — (immigration policy/termination of categorical parole programs (CHNV)) — Massachusetts District Court Judge Indira Talwani granted the plaintiffs' motion for preliminary injunction and granted class certification. The administration appealed. The 1st Circuit initially denied the administration's motion for a stay pending appeal. However, it subsequently entered an order vacating the district court's decision and remanding the case for further proceedings. In the meantime, Talwani granted a second preliminary injunction, which the administration has also appealed. That second appeal is still in the briefing process. 

Three scores to tally here: 

1. Score: ❌ Administration - 0; Challengers - 7
2. Score: ✅ Administration - 1; Challengers - 7
3. Score: ↔️ Administration - 1; Challengers - 7

10. State of California v. U.S Department of Education — (ban on DEIA initiatives) — Massachusetts District Court Judge Myong Joun granted the plaintiffs' motion for a TRO. The administration appealed. The 1st Circuit denied the administration's motion for a stay pending appeal. (The administration then voluntarily dismissed the appeal.)  

Score: ❌ Administration - 1; Challengers - 8

11. Woonasquatucket River Watershed Council v. Department of Agriculture — (freeze on funding appropriated by the Inflation Reduction Act and the Infrastructure Investment and Jobs Act) — Rhode Island District Court Judge Mary McElroy granted the plaintiffs' motion for preliminary injunction. The administration appealed. This one's still in the briefing process.

Score: ↔️ Administration - 1; Challengers - 8

12. State of New York v. McMahon — (dismantling/restructuring of Education Department) — Massachusetts District Court Judge Myong Joun granted the plaintiffs' motion for preliminary injunction. The administration appealed. The 1st Circuit denied the administration's motion for a stay pending appeal on June 4, 2025.

Score: ❌ Administration - 1; Challengers - 9

13. D.V.D. v. U.S. Department of Homeland Security — (deportation to a third country) — This one's another case with multiple 1st Circuit visits: 1) Massachusetts District Court Judge Brian Murphy granted plaintiffs' motion for TRO. The administration appealed. The 1st Circuit denied the administration's motion for a stay pending appeal on April 7, 2025. 2) Murphy then granted plaintiffs' motions for preliminary injunction and class certification. The administration appealed and the 1st Circuit denied its motion for a stay pending appeal on May 16, 2025. 3) Murphy then issued an order instructing the government to maintain custody of the plaintiffs while the case was pending. The administration appealed that order, too. The second and third appeals have now been consolidated and remain in the briefing process. 

Three scores to tally here: 

1. Score: ❌ Administration - 1; Challengers - 10
2. Score: ❌ Administration - 1; Challengers - 11
3. Score: ↔️ Administration - 1; Challengers - 11

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14. Somerville Public Schools v. Trump — (dismantling/restructuring of Education Department) — Massachusetts District Court Judge Myong Joun granted the plaintiffs' motion for preliminary injunction. The administration appealed. The 1st Circuit denied the administration's motion for a stay pending appeal on June 4, 2025.

Score: ❌ Administration - 1; Challengers - 12

15. American Association of University Professors v. Rubio — (habeas corpus/removal of protesters) — Massachusetts District Court Judge William Young presided over a bench trial of the case in July, during which he ruled that the administration had waived certain privileges when it produced documents for the court's review. The administration appealed, seeking a writ of mandamus from the 1st Circuit — which denied the petition. 

Score: ❌ Administration - 1; Challengers - 13

16. State of Colorado v. U.S. Department of Health and Human Services — (termination of public health grants) — Rhode Island District Court Judge Mary McElroy granted plaintiffs' motion for preliminary injunction. The administration appealed to the 1st Circuit, but then subsequently voluntarily dismissed the appeal. 

Score: ↔️ Administration - 1; Challengers - 13

17. American Public Health Association v. National Institutes of Health — (denial of federal grants) — Massachusetts District Court Judge William Young granted partial judgment for the plaintiffs. The administration appealed. The 1st Circuit denied the administration's motion for a stay pending appeal on July 18, 2025. 

Score: ❌ Administration - 1; Challengers - 14

18. State of California v. Trump — (election law) — Massachusetts District Court Judge Denise Casper granted the plaintiffs' motion for preliminary injunction. The administration appealed. The case is still in the briefing stage. 

Score: ↔️ Administration - 1; Challengers - 14

19. Commonwealth of Massachusetts v. Kennedy, Jr. — (denial/termination of federal grants) — Massachusetts District Court Judge William Young granted partial judgment for the plaintiffs. The administration appealed. The 1st Circuit denied the administration's motion for a stay pending appeal on July 18, 2025. 

Score: ❌ Administration - 1; Challengers - 15

20. State of Rhode Island v. Trump — (reduction of the federal bureaucracy) — Rhode Island District Court Judge John McConnell Jr. granted plaintiffs' motion for preliminary injunction. The administration appealed. The 1st Circuit denied the administration's motion for a stay pending appeal on September 11, 2025. 

Score: ❌ Administration - 1; Challengers - 16

21. Association of American Universities v. Department of Energy — (reduction of indirect cost reimbursement rate for research institutions) — Massachusetts District Court Judge Allison Burroughs granted plaintiffs' motion for preliminary injunction. The administration appealed. This one's still being briefed. 

Score: ↔️ Administration - 1; Challengers - 16

22. Victim Rights Law Center v. United States Department of Education — (dismantling of Education Department/closing of Office of Civil Rights) — Massachusetts District Court Judge Myong Joun granted plaintiffs' motion for preliminary injunction. The administration appealed. The 1st Circuit granted the administration's motion for a stay pending appeal. 

Score: ✅ Administration - 2; Challengers - 16

23. Association of American Universities v. National Science Foundation — (NSF "slashing" of indirect cost rates for government-funded research) — Massachusetts District Court Judge Indira Talwani granted plaintiffs' motion for summary judgment. The administration appealed, but subsequently voluntarily dismissed its appeal.

Score: ↔️ Administration - 2; Challengers - 16

24. State of New York v. Kennedy — (dismantling/restructuring of HHS) — Rhode Island District Court Judge Melissa Dubose granted plaintiffs' motion for preliminary injunction. The administration appealed. The 1st Circuit denied the administration's motion for a stay pending appeal on September 17, 2025.

Score: ❌ Administration - 2; Challengers - 17

25. President and Fellows of Harvard College v. United States Department of Homeland Security — (revocation of Student Exchange Visitor program) — Massachusetts District Court Judge Allison Burroughs granted plaintiffs' motion for preliminary injunction. The administration appealed. This one is still being briefed. 

Score: ↔️ Administration - 2; Challengers - 17

26. Barbara v. Trump — (birthright citizenship) — New Hampshire District Court Judge Joseph LaPlante granted plaintiffs' motion for a classwide preliminary injunction. The administration appealed. This one is still being briefed.

Score: ↔️ Administration - 2; Challengers - 17

27. Planned Parenthood Federation of America, Inc. v. Kennedy — (defunding Planned Parenthood) — Massachusetts District Court Judge Indira Talwani granted two separate preliminary injunctions to plaintiffs. The administration appealed both and those appeals have been consolidated. The 1st Circuit granted the administration's motion for a stay pending appeal.

Score: ✅ Administration - 3; Challengers - 17

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28. The Family Planning Association of Maine — (access to healthcare) — Maine Judge Lance Walker denied plaintiffs' motion for preliminary injunction. The plaintiffs appealed. This one is still being briefed.

Score: ↔️ Administration - 3; Challengers - 17

The Final Score

Okay, so here's the final tally so far for the TL;DR crowd: 

Administration - 3; Challengers - 17. 

That's only a 15 percent success rate for the administration before the 1st Circuit Court of Appeals — so...not so hot. 

Now, I'll point out that's just one circuit. And I'll also point out that of the eight 1st Circuit cases that have made it up to Supreme Court, the high court has granted the administration's application for stay or petition for certiorari in six of those (two are awaiting a SCOTUS ruling). 

Lastly, none of the cases has reached final determination on the merits. So, while the Trump administration hasn't fared all that well before the 1st Circuit, I expect we'll see more reversals than not on those cases that do ultimately reach the Supreme Court on the merits.