Federal Judge Halts Trump's Sweeping Demand for Seven Years of Race and GPA Data from College Applicants

A federal court has drawn a line between federal oversight and what 17 state attorneys general called "another witch hunt" — blocking the Trump administration from compelling public universities to surrender vast quantities of student data intended to verify compliance with the Supreme Court's 2023 ban on race-conscious admissions.

The Ruling

U.S. District Judge F. Dennis Saylor IV, sitting in Boston, issued a preliminary injunction on April 3, 2026, barring the Department of Education from enforcing its Admissions and Consumer Transparency Supplement (ACTS) survey against public colleges and universities in the 17 plaintiff states [1]. The injunction replaces a temporary restraining order that had been in place since mid-March.

Saylor did not reject the federal government's authority to collect the data. He wrote that the Department of Education "likely has the statutory authority" to request admissions information, and that antidiscrimination enforcement served "a legitimate purpose" [2]. But he found the manner of implementation fatally flawed. "The 120-day deadline imposed by the President led directly to the failure of NCES to engage meaningfully with the institutions during the notice-and-comment process to address the multitude of problems presented by the new requirements," Saylor wrote [3].

The judge pointed to a specific institutional problem: the administration's simultaneous push to dismantle parts of the Education Department had left the National Center for Education Statistics (NCES) with, by some accounts, "as few as three employees" — raising the question of whether anyone was left to process or secure the data once collected [4].

What the Government Demanded

The ACTS survey, which operationalizes a presidential memorandum issued on August 7, 2025, represents the most expansive federal data collection from higher education institutions in decades [5]. President Trump directed Secretary of Education Linda McMahon to "expand the scope of required IPEDS reporting to provide adequate transparency into admissions," citing the "rampant use of diversity statements and other overt and hidden racial proxies" at American universities [6].

The survey requires roughly 2,200 four-year institutions — every college or university participating in federal student aid programs that uses selective admissions or distributes financial aid — to submit seven years of historical admissions data, broken down by [7]:

• Race and ethnicity of applicants, admitted students, and enrolled students
• Sex
• Unweighted GPA on a 4.0 scale, disaggregated by quintile
• Standardized test scores (SAT/ACT), disaggregated by quintile
• Family income ranges
• Pell Grant eligibility
• Parental education (first-generation status)
• Application round (early action/decision vs. regular)

Data must be cross-tabulated across multiple overlapping categories — race-sex pairings further broken out by GPA quintile, test-score quintile, and income bracket — meaning that each institution could face hundreds of individual data cells to populate [8].

For a system the size of the University of California, which received 251,907 applications for Fall 2026 alone, the retroactive seven-year requirement would encompass records for well over a million applicants across nine undergraduate campuses [9]. The UC and California State University systems told the court the request was "onerous, rushed, risked student privacy and required administrators to track down hard-to-find information for hundreds of thousands of students that individual campuses log differently" [1].

The Legal Battle

Who Sued

Seventeen states filed suit in U.S. District Court for the District of Massachusetts on March 11, 2026: California, Colorado, Connecticut, Delaware, Hawaii, Illinois, Maryland, Massachusetts, New York, Nevada, New Jersey, Oregon, Rhode Island, Vermont, Virginia, Wisconsin, and Washington [10]. New York Attorney General Letitia James called the data demand an effort "to satisfy another witch hunt" [11].

The APA Argument

The states' legal challenge rests primarily on the Administrative Procedure Act (APA), not constitutional grounds. They argue the Education Department "exceeded its statutory authority and failed to comply with the requirements of the Administrative Procedure Act" in adopting the survey [6]. Though the ACTS went through a ninety-day notice-and-comment period before opening on December 18, 2025, the states contend the process was a sham — that the administration ignored the feedback it received and failed to provide clear definitions for the data categories institutions must report on [4].

The states also raised Paperwork Reduction Act (PRA) violations, arguing the survey imposes unreasonable burdens. A survey by the Association for Institutional Research found that 88 percent of institutional research professionals deemed the retroactive reporting requirement "untenable," and 55 percent estimated they would need more than 250 staff hours per institution to compile the data [4].

Why Not a Constitutional Challenge?

The absence of a direct constitutional claim is notable. The states did not primarily argue First Amendment chilling effects, Fourth Amendment privacy interests, or Fourteenth Amendment equal protection. Instead, they chose the procedural route — arguing the government violated its own rulemaking process. This is a pragmatic choice: APA claims require courts to assess whether agencies followed proper procedures, a lower bar than proving constitutional violations.

The Scope Problem

Judge Saylor's injunction protects only public institutions in the 17 plaintiff states [12]. This limitation reflects the Supreme Court's June 2025 decision in Trump v. CASA, Inc., which sharply curtailed so-called "universal" or "nationwide" injunctions. The 6-3 majority held that federal courts lack authority to enjoin executive branch policies as to non-parties, meaning Saylor could not extend protection to institutions nationwide even if he wanted to [13].

For public institutions in the remaining 33 states and private institutions everywhere — including elite schools like Stanford, whose medical school received a separate data demand in late March — the original March 25 deadline stood [14].

The Case for Federal Oversight

The administration's position has a legal foundation that even Judge Saylor acknowledged. The Supreme Court's 2023 decision in Students for Fair Admissions v. Harvard (SFFA) held that race-based admissions programs at Harvard and the University of North Carolina violated the Equal Protection Clause [15]. Chief Justice John Roberts's majority opinion left a narrow opening: applicants could still discuss "how race affected his or her life" in essays, but race could not be used as a categorical factor in admissions decisions.

The question of whether universities actually complied is not hypothetical. The first post-SFFA admissions cycles showed sharp declines in Black and Hispanic enrollment at some institutions — MIT's Black enrollment dropped from 14 percent to 5 percent, and Amherst College's fell from 18 percent to 11 percent [16] — suggesting real changes occurred. But at other institutions, diversity numbers held steady or barely moved, raising suspicions among conservative legal groups.

Source: Various University Reports

Data as of Sep 1, 2025CSV

Students for Fair Admissions, the organization that brought the landmark case, has threatened to sue colleges it accuses of defying the ruling [15]. The Trump administration frames the ACTS survey as a necessary enforcement tool. Education Department spokeswoman Ellen Keast stated: "American taxpayers invest over $100 billion into higher education each year and deserve transparency on how their dollars are being spent" [17].

Teresa R. Manning, writing in American Greatness, argued the data demand is a straightforward exercise of oversight over taxpayer-funded institutions: "Trump's requirement is the administration's effort to implement the Supreme Court's SFFA opinion, which found racial preferences in university admissions unlawful" [17]. Supporters contend that if schools are genuinely complying with SFFA, they should have nothing to hide.

The steelman case for data collection is this: if selective institutions in California and elsewhere are using personal statements, zip codes, or socioeconomic proxies to achieve racial diversity targets that mirror pre-SFFA outcomes, the federal government — which provides over $100 billion annually in student aid — has a legitimate interest in verifying compliance. Without data, enforcement is toothless.

The Privacy Problem

Critics counter that the cure is worse than the disease. The granularity of the data demanded — race cross-tabulated with GPA quintile, test-score quintile, income bracket, and sex — creates what privacy scholars call a re-identification risk: in smaller academic programs, the cell sizes could shrink to the point where individual students become identifiable [11].

Consider a hypothetical: a small engineering program that admitted three Black female students with GPAs above 3.8 and family incomes under $40,000. With enough cross-tabulated categories, "aggregate" data stops being aggregate.

The states warned that "the unprecedented level of detail required by the survey could expose sensitive student information, particularly in smaller academic programs where such data could make individual students identifiable" [4]. This concern is especially acute for:

• Undocumented students, whose presence in public university systems could be exposed through demographic patterns in an era of heightened immigration enforcement
• Low-income and first-generation students, whose financial information would be linked to racial and academic data
• Students at small programs, where cross-tabulation makes anonymity nearly impossible

The American Council on Education (ACE) called the ACTS survey "a fishing expedition," with ACE President Ted Mitchell noting that admissions decisions involve factors like recommendation letters and extracurricular involvement that the data cannot capture [5].

California's Specific Position

California occupies a unique place in this fight. The state banned race-conscious admissions in 1996 through Proposition 209, nearly three decades before the Supreme Court required the rest of the country to follow suit [18]. The UC system has operated without affirmative action longer than any other major public university system in the country.

Source: University of California

Data as of Oct 1, 2025CSV

The UC system's current enrollment reflects this history: Asian American students comprise 25.9 percent, Hispanic/Latino students 24.7 percent, White students 21.3 percent, and Black students 4.2 percent [9]. These numbers are the product of years of race-neutral admissions policies — making California an ironic target for a compliance investigation, since its institutions have the longest track record of operating under the very restrictions SFFA imposed nationwide.

California Attorney General Rob Bonta joined the multi-state coalition, and the state has separately been aggressive in resisting federal data demands across multiple policy areas. In January 2026, Governor Newsom and AG Bonta issued guidance asserting that state and local law enforcement have authority to investigate federal agents who violate California law [19]. While no formal AG opinion specifically addressing CPRA (California Public Records Act) implications of the ACTS survey has been publicly issued, California's broader posture toward federal data requests has been consistently adversarial.

Under FERPA (the Family Educational Rights and Privacy Act), universities can share student data with the Department of Education for authorized purposes — but the states argue the ACTS survey exceeds what FERPA contemplated, particularly given the retroactive seven-year scope and the granularity of the cross-tabulations demanded.

The Compliance Landscape

The practical burden has been substantial even for institutions willing to comply. Lynette Duncan, director of institutional research at John Brown University — a one-person office — spent 20 hours over two weeks retrieving admissions data from 2019 alone [7]. Multiply that across seven years and hundreds of data categories, and the scope becomes clear.

Institutions reported several specific problems [7]:

• Test scores are missing for students admitted under test-optional policies, which expanded dramatically during COVID-19 and have remained common
• Income data is unavailable for students who didn't complete federal financial-aid forms (FAFSA)
• Historical records have been deleted per state data-retention policies requiring destruction after one year
• System migrations have made older records inaccessible or incompatible with current formats

No institution has publicly refused to comply outright, but the data quality concerns suggest that whatever the Department of Education receives may be riddled with gaps and inconsistencies — raising the question of whether the exercise produces useful oversight data or merely creates liability for institutions that submit incomplete reports.

What Happens Next

The legal trajectory of this case depends on several variables.

Immediate timeline: Judge Saylor's preliminary injunction remains in effect while the underlying lawsuit proceeds. The administration can appeal to the First Circuit Court of Appeals (the case is in Massachusetts, not the Ninth Circuit) or seek an emergency stay. Given the Supreme Court's Trump v. CASA limitation on universal injunctions, an appeal focused on broadening or narrowing the injunction's scope is likely [13].

The funding lever: Institutions that fail to comply with IPEDS reporting requirements risk loss of Title IV funding — the federal student aid that most colleges depend on for survival [11]. The administration has not yet threatened specific institutions with funding cuts over the ACTS survey, but the legal framework for doing so exists. Whether the administration pivots to individual enforcement actions against institutions in non-plaintiff states, where the injunction does not apply, remains an open question.

Historical precedent: Federal data disputes with universities tend to move slowly. The Obama-era gainful employment rule, which required career-training programs to prove graduates earned enough to repay student loans, took years to implement, was rescinded by the first Trump administration, and was reinstated by the Biden administration before being rescinded again. The first Trump administration's Title IX guidance went through similar cycles of implementation, litigation, and revision. These precedents suggest the ACTS survey dispute is unlikely to resolve quickly.

The private institution question: Judge Saylor separately extended deadlines for dozens of private institutions while considering whether they also qualify for injunction protection [1]. Private universities like Stanford, which face the same data demands, may need to bring their own legal challenges — or wait for the resolution of the current case.

The fundamental tension is clear: the federal government has a legitimate interest in enforcing the Supreme Court's ruling against race-conscious admissions, and the 17 states and their universities have legitimate concerns about the rushed, burdensome, and privacy-threatening way the administration chose to do it. Judge Saylor's ruling does not resolve that tension — it merely holds that the government must follow proper procedures when it acts on its enforcement authority. How the administration responds will determine whether this becomes a lasting precedent on federal data collection from universities or a procedural speed bump that delays but does not derail the project.