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Legal briefing: general counsel says executive orders alone don't change law; district funding exposure limited

Osseo Public School District School Board · March 12, 2025
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Summary

General counsel told the board that executive orders must be implemented consistent with statutes and appropriations, federal agencies follow enforcement processes, and district federal revenue (~10% of general fund) would not be automatically cut without further administrative or judicial steps.

General Counsel Amy Moore told the board Executive Order 14190 (as cited in the briefing) cannot by itself change statutory text and that enforcement actions by agencies such as the Department of Education proceed through administrative processes, complaint investigations and, where necessary, voluntary compliance agreements or judicial proceedings.

Moore explained the district’s federal funding picture: “our overall federal funding makes up about 10% of our general fund, fund 1 budget,” primarily from Title I–IV grants, USDA child nutrition, and IDEA. In later discussion board members and administration cited a district figure that 10% corresponds roughly to $37,000,000 on a $400,000,000 budget and said the district’s reserves could weather a pause in federal funding for multiple years, though board members asked administration for a formal cost-impact analysis.

Moore also summarized the limits on federal influence in curriculum under the Every Student Succeeds Act and the General Education Provisions Act and noted that if agencies initiated rulemaking or formal enforcement changes the district would receive notice and have an opportunity to participate in the process.