Rosado v. Bondi
Issue
In *Rosado v. Bondi*, Plaintiffs Kassandra Rosado and Kreisau Group LLC argue that a preliminary injunction against alleged government coercion of Meta and Apple must prohibit all forms of official overreach — coercion, threats, pressure, and inducement — as the Supreme Court recognized distinct variants of that conduct in *NRA v. Vullo*, 602 U.S. 175 (2024). The non-obvious difficulty is that translating *Vullo*'s multi-form coercion standard into a Rule 65(d)-compliant injunction requires a court to draw, for the first time, a workable line between prohibited implicit pressure and the government's constitutionally protected right to criticize private platforms — a line neither *Vullo* nor the related *Murthy v. Missouri*, 603 U.S. 43 (2024), has yet drawn in operational terms.
What Happened
Following the court's grant of a preliminary injunction on April 17, 2026 (Dkt. 34), the court directed the parties to submit a joint status report on the form of the injunction order and future scheduling. The parties could not reach agreement on either question, so this May 4, 2026 filing presents their competing positional statements alongside two separate proposed orders — Exhibit A (Plaintiffs') and Exhibit B (Defendants'). Plaintiffs propose broad prohibitory language tracking *Vullo*'s enumerated forms of coercion, aggressive scheduling, and notice obligations extending to Meta and Apple themselves. Defendants argue their narrower formulation — limiting the prohibition to conduct "reasonably understood as a threat of adverse government action" — more faithfully applies *Vullo* while satisfying Rule 65(d)(1)'s specificity requirement, and they request a scheduling timeline consistent with the court's existing stay order. Neither party's proposed order has been adopted by the court.
Why It Matters
The language the court ultimately selects will determine whether government officials can continue the kinds of informal, off-the-record pressure on social media and app platforms that have become routine tools of regulatory influence — making this order-drafting dispute substantively significant despite its procedural form. The competing proposals crystallize two genuinely different readings of *Vullo*: one treating the Supreme Court's multi-verb coercion framework as directly operative, the other reading *Murthy*'s more cautious tone as a narrowing gloss, despite *Murthy* having been resolved on standing grounds without reaching the merits. Whichever order the court adopts is likely to serve as a template — or a foil — for injunctions in future government-platform coercion cases, and the unresolved interaction between *Vullo* and *Murthy* on this precise drafting question is one that courts across the country will eventually have to confront.
Related Filings
Other proceedings in the same litigation tracked by this monitor.
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