The US Eighth Circuit Court of Appeals in St. Louis affirmed a preliminary injunction on Tuesday, which blocks former President Joe Biden’s student debt relief plan from taking effect.

The plaintiffs in the case are the states of Missouri, Arkansas, Florida, Georgia, North Dakota, Ohio and Oklahoma. The defendants include President Donald Trump and Denise Carter, the Secretary of the Department of Education (DOE). Trump and Carter have been substituted as parties to the proceedings per s. 43(c)(2) of the Federal Rule of Appellate Procedure since Biden and his administration have left office.

The seven states initiated the action against the president and the DOE in April 2024, arguing the Saving on a Valuable Education (SAVE) plan, which “altered payment thresholds, stopped interest accrual, and forgave loan balances,” exceeds the statutory authority given to the Secretary. The SAVE plan was subsequently blocked in July 2024 by this same appeals court.

In their appeal, the plaintiffs seek to broaden the injunction while the federal officials want to set the injunction aside. The appeal stems from a district court decision, which ruled the plaintiffs were “likely to succeed on [their] claim and preliminarily enjoined the rule’s early loan forgiveness provisions.” In this case, the appeals court again found the plaintiffs were likely to succeed in their claim and affirmed the district court’s preliminary injunction. However, the appeals court ruled the district court erred by not enjoining the entire SAVE rule, so it remanded the case for further proceedings at the district court.

To support its ruling, the appeals court considered four factors to evaluate a preliminary injunction. The court found each factor supports a preliminary injunction. According to the court, the most important factor to review is the third, which considers whether the plaintiffs will succeed on the merits of their claim. The court employed a textualist analysis and reasoned the Secretary went “well beyond” its authority by designing a plan where loans are mostly forgiven rather than repaid contrary to the power granted to the Secretary by Congress in USC 1087e(d)(1). Thus, it is likely the plaintiffs will succeed in their claim.

This preliminary injunction prevents the SAVE plan from taking effect until a final decision has been made on the plaintiff’s claim. As a result, the forgiveness of “hundreds of millions of dollars of loans” for students earning a post-secondary degree will continue to be suspended.