By Tionna Ryan & Paige Duggins-Clay, J.D. • Federal Education Law and Policy Update • October 9, 2025
Key takeaways
- Federal court blocked exclusion of immigrant children from Head Start.
- Ruling deemed the directive unlawful and discriminatory.
- Head Start remains open to all eligible children.
Resource from the Intercultural Development Research Association (IDRA), a nonprofit advancing education equity.
On September 11, a federal judge in Seattle issued a preliminary injunction immediately blocking the Trump administration’s directive that excluded immigrant children from federally-funded Head Start programs.
The executive action taken by the U.S. Department of Health and Human Services sought to expand the definition of “federal public benefit” under the 1996 Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) to include Head Start.
The administration’s incorrect and discriminatory reinterpretation of the law attempts to deem many immigrant children as ineligible for the first time since the program’s inception 60 years ago.
Head Start is a proven school-readiness program for young children in families with low incomes. Almost one-third of students served are English learners.
The plaintiffs in Washington State Association of Head Start and Early Childhood Assistance and Education Program et al. v. Robert F. Kennedy et al. sought emergency relief to block the directive, arguing that it was contrary to law and that the new interpretation conflicted with PRWORA’s definition of “federal public benefit.”
The court’s decision protects children and families who rely on Head Start programs, which provide crucial early learning support for children and provide critical health, nutrition and family engagement services in marginalized communities.
Access to these critical programs that benefit far more than the children and families directly participating should never be conditioned on immigration status.
This article appeared with other articles in the October 2025 edition of the IDRA Federal Education Law and Policy Update. See the full edition.
FAQs
Q: What was the blocked rule?
A: A directive sought to exclude immigrant children from federally funded Head Start programs.
Q: Why did the court intervene?
A: The rule contradicted federal law and discriminated against children based on immigration status.
Q: Who benefits from this ruling?
A: Children from immigrant families who rely on Head Start for early learning and family services.


