Case 1:25-cv-11472 Document 1 Filed 05/23/25 Page 2 of 72
1. For more than 70 years, Harvard University ("Harvard" or the "University") has been certified by the federal government to enroll international students under the F-1 visa
program, and it has long been designated as an exchange program sponsor to host J-1
nonimmigrants. Harvard has, over this time, developed programs and degrees tailored to its
international students, invested millions to recruit the most talented such students, and integrated
its international students into all aspects of the Harvard community. Yesterday, the government
abruptly revoked that certification without process or cause, to immediate and devastating effect
for Harvard and more than 7,000 visa holders.
2. This revocation is a blatant violation of the First Amendment, the Due Process
Clause, and the Administrative Procedure Act. It is the latest act by the government in clear
retaliation for Harvard exercising its First Amendment rights to reject the government's demands
to control Harvard's governance, curriculum, and the "ideology" of its faculty and students. The government's actions are unlawful for other equally clear and pernicious reasons. They disregard
the government's own regulations-under which Harvard should remain certified to host F-1 and
J-1 visa holders. They depart from decades of settled practice and come without rational
explanation. And they were carried out abruptly without any of the robust procedures the
government has established to prevent just this type of upheaval to thousands of students' lives.
REQUEST FOR RELIEF
WHEREFORE, Harvard respectfully requests the following relief:
A.
Declare that Defendants' actions to revoke Harvard's SEVP certification through
69
Case 1:25-cv-11472 Document 1
Filed 05/23/25
Page 71 of 72
B.
D.
the Revocation Notice are unconstitutional and/or unlawful because they violate
the First Amendment, the Due Process Clause, and the APA;
Preliminarily and permanently enjoin Defendants, their agents, and anyone acting
in concert or participation with Defendants from implementing, instituting,
maintaining, or giving effect to the unlawful revocation of Harvard's SEVP
certification;
Preliminarily and permanently enjoin Defendants, their agents, and anyone acting
in concert or participation with Defendants from giving any force or effect to the
Department of Homeland Security's May 22, 2025 Revocation Notice;
Permanently enjoin Defendants, their agents, and anyone acting in concert or participation with Defendants from issuing a NOW or otherwise initiating
proceedings to withdraw Harvard's SEVP certification in retaliation for Harvard's
exercise of its rights under the First Amendment, or because of the viewpoint of
Harvard's First Amendment protected speech, or because of Harvard's refusal to
comply with the April 11 Demand Letter.
Here is Harvard's new lawsuit, over the international student revocation, filed by the same team of lawyers behind the first lawsuit: storage.courtlistener.com/recap/gov.us...
23.05.2025 12:53 β π 868 π 190 π¬ 22 π 11
ngl something about the lack of priv on bluesky makes me feel so exposed i lose motivation to come here
23.05.2025 17:11 β π 0 π 0 π¬ 1 π 0
purplemath
It's a grim day in one of the grimmest weeks in recent memory, but we keep going. We'll be live at 4 PM ET to discuss the apparent demises of Polygon and Giant Bomb, as well as EA layoffs and one recent development we're actually enjoying: Clair Obscur, which rules
www.twitch.tv/aftermathdot...
01.05.2025 18:29 β π 175 π 25 π¬ 0 π 4
hell actually isn't hot enough for these people
16.04.2025 18:10 β π 2 π 0 π¬ 0 π 0
The first and most important thing to know about last night's Exec order is that it's intended to break current law and allow people throughout the federal gov look at yr tax returns. Beyond that it's intended to compel states to turn over all their data to the fed govt.
22.03.2025 15:44 β π 12666 π 4564 π¬ 320 π 610
it's almost like, and bear with me on this, public opinion might move on these issues if there was a whole network of politicians, pundits, and aligned media doing everything in their power to highlight the abuses and unpopular aspects of the deportation regime instead of triangulating on it
21.03.2025 19:08 β π 1144 π 269 π¬ 15 π 5
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
PERKINS COIE LLP,
Plaintiff,
V.
U.S. DEPARTMENT OF JUSTICE, et al.,
Defendants.
Civil Action No. 25-0716 (BAH)
NOTICE OF WITHDRAWAL
Undersigned counsel, Terry M. Henry, will soon be retiring from the United States
Department of Justice and requests that the Clerk of the Court please remove his appearance as counsel for Defendants in the above-captioned case. Defendants will continue to be represented by lead counsel, Deputy Associate Attorney General Richard Lawson, and any other Department of Justice attorneys who enter an appearance.
Dated: March 21, 2025
Washington, D.C.
Respectfully submitted,
/s/ Terrv M. Henry
TERRY M. HENRY
United States Department of Justice
Civil Division
Federal Programs Branch
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
PERKINS COIE LLP,
Plaintiff,
Civil Action No. 1:25-cv-00716-BAH
V.
U.S. DEPARTMENT OF JUSTICE, et al.,
Defendants.
DEFENDANTS' MOTION TO DISQUALIFY
JUDGE BERYL HOWELL
Fair proceedings free from any suggestion of impartiality are essential to the integrity of our country's judiciary and the need to curtail ongoing improper encroachments of President Trump's Executive Power playing out across the country. In this case, reasonable observers may
well view this Court as insufficiently impartial to adjudicate the meritless challenges to President
Trump's efforts to implement the agenda that the American people elected him to carry out. In
fact, this Court has repeatedly demonstrated partiality against and animus towards the President.
CONCLUSION
Defendants deserve a court proceeding free from concerns about impartiality. In order to
remove the possibility of any impartiality to these proceedings, Defendants respectfully request
that this Court recuse itself and return this matter to assignment before a judge free from any
appearance of hostility toward this Administration and is otherwise unconnected with any matter
related to the Mueller Report or Durham Investigation.
Dated: March 21, 2025 Respectfully Submitted,
Washington, DC
CHAD MIZELLE
Acting Associate Attorney General
/s/ Richard Lawson
RICHARD LAWSON
Deputy Associate Attorney General
BREAKING: DOJ files a motion to recuse Judge Beryl Howell from the Perkins Coie case β shortly after one of the three lawyers on the case, Terry Henry, withdraws.
DOJ alleges that Howell has shown "partiality against and animus towards the President," signed by Chad Mizelle and Richard Lawson.
21.03.2025 19:18 β π 520 π 140 π¬ 55 π 31
Going further into debt to buy crypto is basically every crypto bro's investment strategy
02.03.2025 17:21 β π 578 π 142 π¬ 55 π 21
perf let me loop back after my trial this week!!
19.11.2024 04:34 β π 0 π 0 π¬ 0 π 0
i wish this was elevator etiquette where i live but if i don't tell someone to have a "nice day" when i get off the elevator, i feel like i've broken some social code
19.11.2024 03:41 β π 0 π 0 π¬ 0 π 0
first i suggest emily in paris (i haven't figured out a window when i'm free yet so probably december)
19.11.2024 03:37 β π 0 π 0 π¬ 1 π 0
i wish i could say i am better than this but no i need a rotating main character to grasp my attention on any social media site
17.11.2024 05:23 β π 0 π 0 π¬ 0 π 0
how do i boost this to my discover feed...serious answers only
17.11.2024 05:22 β π 0 π 0 π¬ 1 π 0
15.11.2024 12:46 β π 24437 π 1330 π¬ 525 π 109
is bluesky rockin with the crocheted sweaters on the yakuza hangers
#crochet
13.11.2024 22:48 β π 190 π 28 π¬ 5 π 3
yeah exactly lmao i couldn't even see my mutuals on twitter anymore, which defeated the whole point for me
15.11.2024 07:38 β π 2 π 0 π¬ 0 π 0
yeah!! i should be more active here than twitter i think!
15.11.2024 07:35 β π 1 π 0 π¬ 1 π 0
@liny.bsky.social followed back!!
14.11.2024 20:34 β π 0 π 0 π¬ 0 π 0
@basicbaka.bsky.social just followed!
14.11.2024 20:16 β π 1 π 0 π¬ 0 π 0
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