Which Trump administration executive actions have been overturned as unlawful under the Administrative Procedure Act?
Executive summary
Federal courts have repeatedly used the Administrative Procedure Act (APA) to block, vacate, or preliminarily enjoin multiple Trump administration actions, but there is not a single, authoritative public list in the supplied reporting that catalogs every APA vacatur; instead, the litigation landscape is dynamic and tracked by public projects that count dozens of government actions blocked or challenged [1]. Reporting shows specific high-profile rulings where judges granted relief that functionally halted executive measures — including a certified class-action injunction against an attempt to end birthright citizenship and a preliminary block on restrictions the administration sought to impose on press access — but many suits remain pending and outcomes vary by court [2].
1. Courts have set aside and enjoined a large number of actions, but the only comprehensive evidence is litigation trackers
Legal trackers maintained by organizations such as Just Security document hundreds of lawsuits challenging Trump administration executive actions and report many instances where government action has been blocked, temporarily enjoined, or vacated — the tracker tallies dozens of government actions blocked and hundreds of cases pending or resolved in plaintiffs’ favor, reflecting broad use of the APA by challengers [1]. Those tallies show judicial willingness to provide nationwide relief under the APA in certain circumstances, a point litigants have leaned on after the Supreme Court’s recent decisions reshaping administrative law [3].
2. Examples reported in the press: birthright-citizenship rollback and media-access restrictions
Mainstream reporting identifies several concrete instances in which federal judges halted Trump administration policies: a federal judge certified a class and blocked enforcement of an executive order the administration issued attempting to end birthright citizenship, and another ruling found that barring The Associated Press from certain events violated the First Amendment and enjoined elements of the administration’s press restrictions [2]. These are examples where courts intervened in response to legal challenges; the New York Times’ litigation timeline lists multiple other preliminary injunctions and ongoing appeals across policy areas [2].
3. Many deregulatory directives have been targeted under APA challenges even before final judicial resolution
The Trump administration’s sweeping April 9, 2025 deregulatory orders and memoranda, which directed agencies to repeal rules alleged to be “unlawful” and encouraged use of the APA’s “good cause” exception to avoid notice-and-comment, have produced numerous lawsuits asserting APA violations; commentators and law firms warn that foreclosing notice-and-comment or pre‑determining outcomes would likely generate successful APA challenges because the statute requires reasoned explanations and public procedures [4] [5]. Legal advisors and firms expressly predict litigation over those rescissions and note agencies’ own statements may create road maps for APA challenges [6] [4].
4. Administration strategies to evade APA review — and judicial pushback — are central to the dispute
The administration has pursued strategies to minimize judicial review, including asserting broad foreign-affairs or presidential exemptions for trade, immigration, and national-security actions and directing agencies to rely on “good cause” to bypass notice-and-comment; analysts and policy centers caution those moves could be litigated and are unlikely to immunize many actions from APA challenge, while scholars note constitutional and statutory arguments may limit the APA’s reach in a subset of trade and national-security decisions [7] [8] [5]. Courts, for their part, have already demonstrated readiness to grant nationwide relief under the APA in appropriate cases, and trackers show plaintiffs successfully obtaining vacatur or injunctions in numerous matters even as many cases remain unresolved on appeal [3] [1].
Conclusion: concrete overturnings exist but no single public source in the supplied reporting enumerates every APA vacatur
The supplied reporting confirms multiple instances in which federal courts have enjoined or otherwise blocked Trump administration executive actions under APA theories — exemplified by the birthright-citizenship injunction and press-access rulings and reflected in Just Security’s litigation tracker — but it does not present a definitive, itemized list of every executive action that has been formally overturned under the APA; assembling such a list requires following the trackers and individual court opinions as they issue [2] [1]. The administration’s programmatic attempts to sidestep APA procedures ensure continued waves of litigation, meaning the inventory of vacated or enjoined actions will keep evolving [6] [5].