U.S. District Judge Beryl Howell ruled that the Department of Health and Human Services must halt enforcement of new requirements imposed on recipients of federal teen pregnancy prevention grants. 

The lawsuit arose from a July 2025 policy notice issued by HHS Secretary Robert F. Kennedy Jr.’s department that required recipients of Teen Pregnancy Prevention Program (TPP) grants to align their programming with a series of executive orders signed by President Trump.

The policy specifically required grant recipients to eliminate content that the administration deemed inappropriate, including materials supporting LGBTQ+ individuals, diversity and inclusion initiatives, and comprehensive sex education approaches. The policy warned that non-compliance could result in grant termination and potential clawback of previously allocated funds.

Three Planned Parenthood affiliates, located in California, Iowa, and New York, filed suit in federal court, arguing they faced an impossible choice: either comply with requirements they believed would undermine evidence-based programming mandated by Congress, or forfeit critical federal funding.

Howell found that the July Policy Notice was “arbitrary and capricious” in violation of the Administrative Procedure Act, criticizing the policy as being “motivated solely by political concerns, devoid of any considered process or analysis, and ignorant of the statutory emphasis on evidence-based programming.”

Under the contested policy, organizations were required to ensure their programming did not include what HHS termed “ideological content” related to gender identity, same-sex relationships, or comprehensive approaches to sexual health education. The administration argued this was necessary to ensure “taxpayer funds do not support content that undermines parental rights, promotes radical gender ideology, or exposes children to sexually explicit material under the guise of public health.”

“Just because a pronouncement comes from the President does not make it true, even if expressed in the form of an executive order, and even then, does not supersede the law—particularly in the context of a statutory scheme for evidence-based grant funding,” she wrote. “Yet, the Policy Notice points to little more than these orders for justification.”

The court determined that the HHS policy imposed “binding legal obligations” on grant recipients while being “incomprehensibly vague,” creating an environment susceptible to arbitrary enforcement. Judge Howell noted that the policy failed to provide adequate guidance on how organizations could demonstrate compliance, exposing them to potential penalties without clear standards.

The court found that HHS had failed to provide proper justification for the policy change, noting the absence of “declarations, memoranda, email correspondence, or other documentation detailing how it reached the decision to implement the policy.”

Judge Howell’s decision focused on how the policy’s vagueness violated due process protections and created conditions for arbitrary enforcement. The court found that regulated entities should not be subjected to unclear requirements that expose them to significant penalties without adequate notice of what compliance entails.

The ruling also implicated the Supreme Court’s recent decision in Mahmoud v. Taylor (2025), which established stronger parental rights regarding religious opt-outs from school curricula. The HHS policy had cited this decision as justification for requiring advance parental notice and opt-out opportunities for certain content, though the court found this application exceeded the agency’s authority.

Congress allocated over $100 million annually for evidence-based initiatives aimed at reducing teenage pregnancy rates through the Teen Pregnancy Prevention Program. The program funds both public and private organizations, including nonprofits, health departments, Native American tribes, and universities across the nation.

The ruling immediately prohibits HHS from enforcing the July policy against the Planned Parenthood plaintiffs and other similarly situated organizations. During the litigation, the three plaintiff organizations had refrained from accessing their approved grant funds rather than risk potential clawback penalties, with one organization forced to halt programming entirely while the others used internal reserves to continue operations.

The decision affects not only the specific Planned Parenthood affiliates involved in the lawsuit but also dozens of other organizations nationwide that receive TPP funding, including community health centers, educational institutions, and tribal organizations. These entities can now continue operating under their original grant terms while the broader legal challenges to the administration’s policies continue.