From a Heritage Shake-Up to Court Dockets: Tracing Project 2025's Ideas Through October 2026
The head of Project 2025 stepped down after Trump criticized the project 29.

In short
The checked evidence shows that the project's leadership shook up after criticism from both Democrats and Trump, while the project said its work would continue 2930. Reporting centered on a candidate database of more than 10,000 vetted names, and the transition's public account conflicts with reports that some of those names were being used 1234. Many of the most documented follow-up steps fall into two areas: removal power over independent agency members, where the Supreme Court has overruled Humphrey's Executor and declined to revive Wilcox's NLRB case 5138, and civil service protections, where Schedule F was revived in 2025 and renamed Schedule Policy/Career, a new job classification for "policy-related" positions, and the American Federation of Government Employees' national president has promised an "imminent" court challenge to the rule 7375. On immigration, a three-judge D.C. Circuit panel blocked Trump's order suspending asylum access at the southern border, though earlier legal action had already paused the asylum ban, and ICE has received more than $75 billion to expand operations since Trump returned to office 61132.
July 2024: A leadership shake-up at Heritage
In late July 2024, a cited Wall Street Journal article reported that the head of Project 2025 stepped down after Trump criticized the project 29. An Associated Press article cited in the same record said the project shook up its leadership after criticism from both Democrats and Trump, while saying its work would continue 30.
September to November 2024: The candidate database
In September 2024, transition official Howard Lutnick said the Trump transition team had not touched the Project 2025 database and had not gone near it 4. Later reporting described officials overseeing plans for some departments and agencies who had started reaching out to potential hires whose names and contact information came from the Project 2025 database 1. A person who worked on Project 2025 said the transition was still sending names, including ones from the database, for open positions 2. The database contained more than 10,000 candidates vetted for their MAGA credentials to build out a Trump administration 3.
The transition also rejected a push to make Roger Severino, who wrote the Project 2025 HHS chapter, deputy secretary of Health and Human Services 5.
Early 2025: Orders, firings, and first lawsuits
In January 2025, an executive order directed DHS to detain individuals apprehended for immigration violations to the extent permitted by law and to allocate all available resources to ICE detention 37. In January 2025, DHS issued a Federal Register notice restoring the scope of expedited removal to the fullest extent Congress authorized, and it took effect without prior notice and comment 5456. On January 27, Trump ordered Wilcox fired from the NLRB and notified her by email 46.
In February 2025, Trump fired one-third of the members of the Merit Systems Protection Board 72, and a Merit Systems Board member sued over her firing 76. A federal judge ruled on March 4, 2025 that Trump's firing of the merit board chair was illegal 78. On March 6, a district court found Wilcox's removal unlawful and held that she remained an NLRB member 49.
On March 13, 2025, a federal judge ordered thousands of federal workers reinstated and criticized the government's declaration as a 'sham' 80.
Mid-2025 to mid-2026: Courts, rules, and reclassification
The Supreme Court allowed the Trump administration to carry out a reduction in force at the Education Department 28. In the environment area, the Office of Surface Mining Reclamation and Enforcement's 2025 direct final rule lifts the suspension of the subsidence provision and removes paragraphs that set up a rebuttable presumption of causation for damage near underground mines 59. The rule was published November 28, 2025, became effective January 27, 2026, and was not withdrawn despite one substantive comment 67. Separately, the siltation structure provisions were struck down by a reviewing court in 1985, have no legal effect, and were never removed from the Code of Federal Regulations 61.
The D.C. Circuit overturned the March 2025 district court ruling that had found Wilcox's firing unlawful, holding 2-1 that Trump's decision to remove him was within his constitutional authority 47. Schedule F, revived in 2025 and renamed Schedule Policy/Career, is a new job classification within the excepted service for 'policy-related' positions 73. Officials estimated that about 50,000 federal workers would lose their civil service protections starting roughly a month after a February 2026 article 71. Of more than 40,000 public comments on the proposed rule, 94% opposed the policy 77, and the American Federation of Government Employees' national president promised an 'imminent' court challenge to the rule, coordinated with other employee groups 75.
On April 24, 2026, a three-judge D.C. Circuit panel ruled that immigration laws give people the right to apply for asylum at the border and blocked Trump's order suspending asylum access at the southern border 6. Judge Justin Walker partly dissented but agreed the president cannot strip mandatory removal-protection procedures 10. In June 2026, the Supreme Court's decision in Trump v. Slaughter overruled Humphrey's Executor and held that Congress may not restrict the president's power to fire members of multi-member independent agencies that exercise executive power 51.
Where things stand now (October 2026)
The money trend is clear in the record. ICE has received more than $75 billion to expand operations since President Trump returned to office 32, and the 2026 reconciliation bill gives DHS until September 2029 to spend its immigration enforcement funds 15. The House Appropriations Committee approved an additional $28 billion for ICE and CBP for fiscal 2027 25. The asylum ban remains blocked, though the order does not take effect until the court considers any rehearing request 11.
The cited facts do not show that Project 2025 formally withdrew any specific proposals. They show a leadership change: its head stepped down after Trump criticized the project 29, and the Associated Press reported a leadership shake-up after criticism from both Democrats and Trump, with the group saying its work would continue 30. On the transition side, Howard Lutnick said the Trump transition team had not touched the Project 2025 database and had not gone near it 4, and the transition rejected a push to make Roger Severino, who wrote the Project 2025 HHS chapter, deputy secretary of Health and Human Services 5. The cited facts do not address the Schedule Policy/Career challenge, so its outcome is not established here.
Still unknown
The checked evidence does not include a dated source for when the Mandate for Leadership book was published or whether it was openly released, so that publication point is not confirmed here.
It is not established how closely the specific 2025 and 2026 actions, such as the asylum order, the ICE funding, and the OSM rules, follow particular pages of the Mandate's text.
Reports disagree about whether the Project 2025 database was used for hiring: the transition denied touching it, while other reports describe names from it still being sent for open jobs.
Justice and FBI, health and abortion, and family and gender policy lanes have little or no checked evidence, so their status by October 2026 is not settled. The Schedule Policy/Career challenge outcome is also unknown.
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Sources
"officials overseeing plans for some departments and agencies have started to reach out to potential hires whose names and contact information were part of that database."trump team turns project 2025 disavowing effort campaign rcna180689
""There's a lot of positions to fill and we continue to send names over, including ones from the database as they are conservative, qualified and vetted," the person, who worked on Project 2025, said."trump team turns project 2025 disavowing effort campaign rcna180689
"the group built a database of more than 10,000 candidates vetted for their MAGA credentials who would build out the administration in the event Trump won"trump team turns project 2025 disavowing effort campaign rcna180689
""The transition team of Donald Trump has not touched it, has not gone near it," he said."trump team turns project 2025 disavowing effort campaign rcna180689
"the transition rejected a push for former Trump administration official Roger Severino, who wrote Project 2025's chapter on the Department of Health and Human Services, to serve as deputy secretary of the agency"trump team turns project 2025 disavowing effort campaign rcna180689
"A three-judge panel from the U.S. Court of Appeals for the District of Columbia Circuit found that immigration laws give people the right to apply for asylum at the border, and the president can't circumvent that."Appeals court rules Trump's asylum ban at southern border is illegal : NPR
"The panel concluded that the Immigration and Nationality Act doesn't authorize the president to remove the plaintiffs under "procedures of his own making," allow him to suspend plaintiffs' right to apply for asylum or curtail procedures for adjudicating their anti-torture claims."Appeals court rules Trump's asylum ban at southern border is illegal : NPR
"the now-enjoined Global Asylum final rule"Security Bars and Processing; Delay of Effective Date (Homeland Security Department, Justice Department, 2024-12-27)
""The power by proclamation to temporarily suspend the entry of specified foreign individuals into the United States does not contain implicit authority to override the INA's mandatory process to summarily remove foreign individuals," wrote Judge J. Michelle Childs, who was nominated to the bench by Democratic President Joe Biden."Appeals court rules Trump's asylum ban at southern border is illegal : NPR
"Walker, however, agreed with the majority that the president cannot deport migrants to countries where they will be persecuted or strip them of mandatory procedures that protect against their removal."Appeals court rules Trump's asylum ban at southern border is illegal : NPR
"Aaron Reichlin-Melnick, senior fellow at the American Immigration Council, said that previous legal action had already paused the asylum ban, and the ruling won't change much on the ground."Appeals court rules Trump's asylum ban at southern border is illegal : NPR
"was enacted on April 30, 2026, funding all of DHS except for the U.S. Border Patrol (USBP) and U.S. Immigration and Customs Enfor"Department of Homeland Security Appropriations: FY2026 State of Play
"U.S. Immigration and Customs Enforcement (ICE)—$74.85 billion, including:"Understanding the FY2026 DHS Budget Request
"The FY 2026 Budget includes $11.3B, 21,808 positions, and 21,786 full-time equivalents (FTE) for U.S. Immigration and Customs Enforcement (ICE)."Dhs
"The 2026 reconciliation bill, dubbed the Secure America Act, gives DHS until September 2029 to spend the money."ICE and Customs and Border Protection Budgets to Exceed $200 Billion
"Detention Capacity is increased by $501.0M to support 50,000 beds."Dhs
"FY 2026 FTE Adjustment - (29) - - -"U.S. Immigration and Customs Enforcement Budget Overview
"Over half the new funds will go to ICE, which will receive nearly $39 billion for a wide range of enforcement operations, including additional hiring, facilities, and arrests."ICE and Customs and Border Protection Budgets to Exceed $200 Billion
"The Budget increases Transportation and Removal Operations with an increase of $205.0M to fund detainee domestic movement as well as increased funding for international removals for aliens with final orders of removal."Dhs
"Non-recur of FY 2025 Anomaly - - ($121,382) ($363,618) ($485,000)"U.S. Immigration and Customs Enforcement Budget Overview
"Congress also gave CBP $26 billion to hire more personnel and conduct immigration enforcement, as well as to expand air, sea, and border surveillance."ICE and Customs and Border Protection Budgets to Exceed $200 Billion
"FY 2025 TO FY 2026 Change - 19 $4,423 $373,483 $377,906"Dhs
"The detention contract costs are projected to increase from $1.9B to $2.1B in FY 2026."U.S. Immigration and Customs Enforcement Budget Overview
"Even if ICE and CBP evenly spread the reconciliation funds in the Secure America Act and the July 2025 reconciliation through their expiration in September 2029, the combined budgets of ICE and CBP will have more than tripled since 2021."ICE and Customs and Border Protection Budgets to Exceed $200 Billion
"The House Appropriations Committee just approved an additional $28 billion for ICE and CBP for fiscal year 2027, which starts this fall."ICE and Customs and Border Protection Budgets to Exceed $200 Billion
"Education Department outsourcing is unlawful, amended lawsuit alleges"Education Department outsourcing is unlawful, amended lawsuit alleges
"Even when programming shifts under the interagency agreements, the Education Department would still be the agency responsible for these programs"Education Department outsourcing is unlawful, amended lawsuit alleges
"Supreme Court Permits Trump Administration to Carry Out Reduction in Force at ED"Financial Aid Litigation
"Head of Project 2025 Steps Down Following Trump Criticism"The Heritage Foundation
"Project 2025 shakes up leadership after criticism from Democrats and Trump, but says work goes on"The Heritage Foundation
"Trump allies at Heritage declare 2024 election illegitimate in advance"The Heritage Foundation
"ICE has received more than $75 billion to expand operations since President Trump returned to office"ICE wasted millions on detention without strategic plan, GAO says - Axios
"Since January 2025, ICE invested billions of dollars in six new initiatives without conducting necessary analysis and planning."Immigration Detention: Urgent Planning Needed to Avoid Further Waste of ...
"and wasted millions on scaled-back and mismanaged projects, a new GAO report found"ICE wasted millions on detention without strategic plan, GAO says - Axios
"ICE purchased 11 warehouses to renovate for detention purposes at a reported cost of about $1.07 billion."Immigration Detention: Urgent Planning Needed to Avoid Further Waste of ...
"Given ICE’s unprecedented multi-year detention funding and the potential for continued waste of taxpayer dollars, more timely completion may be warranted."Immigration Detention: Urgent Planning Needed to Avoid Further Waste of ...
"A January 2025 Executive Order directed the Department of Homeland Security (DHS) to detain individuals apprehended for violations of immigration law to the extent permitted by law and to allocate all available resources for ICE detention purposes."Immigration Detention: Urgent Planning Needed to Avoid Further Waste of ...
"The justices turned away former NLRB member Gwynne Wilcox's appeal of a lower court's ruling that said the Republican president's January 2025 firing of her was a valid exercise of executive authority."Supreme Court won't review Trump's firing of labor board member
"A district judge previously ordered Harper and Otsuka reinstated. An appellate stay subsequently kept both former officials away from the board."Supreme Court Rejects Agency Firing Appeal as NCUA Board Fight Continues
"The justices turned down Wilcox’s petition on Oct. 19 in an unsigned order . No justices dissented. No reasons were provided."Supreme Court Lets Trump’s Firing of NLRB Member Stand
"That ruling was reversed in a 2-1 decision by the U.S. Court of Appeals for the District of Columbia Circuit in December 2025, prompting Wilcox's appeal to the Supreme Court."Supreme Court won't review Trump's firing of labor board member
"But a divided federal appeals court reversed that ruling."Supreme Court Rejects Agency Firing Appeal as NCUA Board Fight Continues
"The decision leaves intact a December 2025 ruling by the U.S. Court of Appeals for the District of Columbia Circuit that the president may remove NLRB members at will."Supreme Court Lets Trump’s Firing of NLRB Member Stand
"The court's action follows its June decision backing Trump's firing of Rebecca Slaughter, a Democratic Federal Trade Commission member."Supreme Court won't review Trump's firing of labor board member
"The decision effectively ends Wilcox’s legal effort to regain her position"Supreme Court Hands Trump Major Win In Biden Appointee Firing Case
"Trump ordered Wilcox fired on Jan. 27, 2025, and notified her by email."Supreme Court Lets Trump’s Firing of NLRB Member Stand
"That decision was subsequently overturned by the U.S. Court of Appeals for the District of Columbia Circuit in December 2025."Supreme Court Hands Trump Major Win In Biden Appointee Firing Case
"Nor did it order Harper and Otsuka returned."Supreme Court Rejects Agency Firing Appeal as NCUA Board Fight Continues
"Wilcox sued in federal district court in Washington and won a summary judgment on March 6, 2025, that said her removal was “unlawful” and that she “remains a member” of the NLRB"Supreme Court Lets Trump’s Firing of NLRB Member Stand
"In that case, the justices ruled 6-3 in favor of Trump’s removal authority, overturning a major legal precedent dating back to 1935."Supreme Court Hands Trump Major Win In Biden Appointee Firing Case
"It follows the Supreme Court’s June 29 decision in Trump v. Slaughter, which overruled the 1935 precedent, Humphrey’s Executor v. United States, and held that Congress may not restrict the president’s power to fire members of multi-member independent agencies that exercise executive power."Supreme Court Lets Trump’s Firing of NLRB Member Stand
"On October 30, 2025, DHS published an interim final rule (IFR) that amended DHS regulations to end the practice of automatically extending the validity of employment authorization documents (Forms I-766 or EADs) for aliens who have timely filed an application to renew their EAD in certain employment authorization categories."Removal of Automatic Extensions for Certain Employment Authorization Documents (Homeland Security Department, 2026-10-14)
"DHS issued a final rule to amend regulations concerning the statutory 9-11 Response and Biometric Entry-Exit Fee for H-1B and L-1 Visas"What changed on www.uscis.gov/working-in-the-united-states/h-1b-specialty-occupations between 2021-07-06 and 2026-10-03
"This Notice also restores the scope of expedited removal to the fullest extent authorized by Congress."Designating Aliens for Expedited Removal (Homeland Security Department, 2025-01-24)
"With this final rule, DHS is adopting and finalizing the changes made by the IFR and not making any additional changes to the regulations."Removal of Automatic Extensions for Certain Employment Authorization Documents (Homeland Security Department, 2026-10-14)
"this designation is effective without prior notice and comment or a delayed effective date."Designating Aliens for Expedited Removal (Homeland Security Department, 2025-01-24)
"advises that the interim final rule is rescinded effective immediately."Rescission of Interim Final Rule, Evaluative Rating: Impact of Medication (Veterans Affairs Department, 2026-02-27)
"The direct final rule removes paragraphs that required that all surface drainage from the disturbed area pass through a siltation structure before leaving the permit area."Rescission of Portions of Permanent Program Performance Standards Related to Siltation Structures (Interior Department, Surface Mining Reclamation and Enforcement Office, 2026-01-27)
"The direct final rule lifts the suspension of the regulatory provision and revises the Federal regulations to remove paragraphs related to establishing a rebuttable presumption of causation"Rescission of Portions of Permanent Program Performance Standards Regulating Subsidence Controls for Underground Mines (Interior Department, Surface Mining Reclamation and Enforcement Office, 2026-01-27)
"published in the Federal Register on February 17, 2026. 91 FR 7118."Rescission of Interim Final Rule, Evaluative Rating: Impact of Medication (Veterans Affairs Department, 2026-02-27)
"These provisions were struck down by a reviewing court in 1985 and have no legal effect but were never removed from the Code of Federal Regulations."Rescission of Portions of Permanent Program Performance Standards Related to Siltation Structures (Interior Department, Surface Mining Reclamation and Enforcement Office, 2026-01-27)
"In response to the court's holding, OSMRE suspended these provisions on December 22, 1999, but did not remove the language from the Code of Federal Regulations."Rescission of Portions of Permanent Program Performance Standards Regulating Subsidence Controls for Underground Mines (Interior Department, Surface Mining Reclamation and Enforcement Office, 2026-01-27)
"finds that prior notice and comment for this rescission is"Rescission of Interim Final Rule, Evaluative Rating: Impact of Medication (Veterans Affairs Department, 2026-02-27)
"for the District of Columbia remanded these provisions to OSM on July 15, 1985, because the court found OSM's rationale for these provisions flawed, and OSM later suspended them."Rescission of Portions of Permanent Program Performance Standards Related to Siltation Structures (Interior Department, Surface Mining Reclamation and Enforcement Office, 2026-01-27)
"paragraphs (c)(4)(i) through (c)(4)(iv) of 30 CFR 817.121 should be rescinded because they were vacated by court order in 1999"Rescission of Portions of Permanent Program Performance Standards Regulating Subsidence Controls for Underground Mines (Interior Department, Surface Mining Reclamation and Enforcement Office, 2026-01-27)
"Douglas A. Collins, Secretary of Veterans Affairs, approved this"Rescission of Interim Final Rule, Evaluative Rating: Impact of Medication (Veterans Affairs Department, 2026-02-27)
"is confirming the effective date of January 27, 2026, for the direct final rule"Rescission of Portions of Permanent Program Performance Standards Related to Siltation Structures (Interior Department, Surface Mining Reclamation and Enforcement Office, 2026-01-27)
"The effective date of the rule published November 28, 2025, at 90 FR 54577 is confirmed as January 27, 2026."Rescission of Portions of Permanent Program Performance Standards Regulating Subsidence Controls for Underground Mines (Interior Department, Surface Mining Reclamation and Enforcement Office, 2026-01-27)
"This action does not resolve the legal questions now before the courts; it simply restores prior regulatory text to maintain stability."Rescission of Interim Final Rule, Evaluative Rating: Impact of Medication (Veterans Affairs Department, 2026-02-27)
"Over 25 years ago, the provisions identified in the direct final rule were struck down on judicial review because the court found that OSM failed to provide adequate support to justify its presumption that damage was the result of mining within the angle of draw."Rescission of Portions of Permanent Program Performance Standards Regulating Subsidence Controls for Underground Mines (Interior Department, Surface Mining Reclamation and Enforcement Office, 2026-01-27)
"Officials estimate that around 50,000 federal workers will be stripped of their civil service protections beginning in around a month, as unions, employee associations and good government groups decry their positions’ politicization."Trump admin moves to finalize return of Schedule F - Government Executive
"Trump fires one-third of federal employee appeals board"Domestic policy of the second Trump administration
"First developed during Trump’s first term and revived last year, Schedule F—now renamed Schedule Policy/Career—is a new job classification within the government’s excepted service for “policy-related” positions."Trump admin moves to finalize return of Schedule F - Government Executive
"It was rescinded by President Biden as soon as he took office in January 2021."The Schedule F Threat to Democracy: A Project 2025 Explainer - Kettering Foundation
"And Everett Kelley, national president of the American Federation of Government Employees, promised an “imminent” court challenge to the rule, in coordination with other employee groups."Trump admin moves to finalize return of Schedule F - Government Executive
"Merit Systems Board Member Harris Sues Trump Over Firing (2)"Domestic policy of the second Trump administration
"Fully 94% of the more than 40,000 comments submitted on the proposed rule were opposed to the policy."Trump admin moves to finalize return of Schedule F - Government Executive
"Federal judge rules Trump's firing of merit board chair was illegal"Domestic policy of the second Trump administration
"“This new designation can be used to remove expert career federal employees who place the law and service to the public ahead of blind loyalty and replace them with political supporters who will unquestioningly do the president’s bidding.”"Trump admin moves to finalize return of Schedule F - Government Executive
"Judge orders thousands of federal workers reinstated; slams 'sham' government declaration"Domestic policy of the second Trump administration
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