From the judge’s memorandum (Defendents = Trump):
It also holds that Defendants unlawfully promulgated the rule without complying with the APA’s notice-and-comment requirements, because neither the “good cause” nor the “foreign affairs function” exceptions are satisfied on the record here. The Court thus need not reach Plaintiffs’ other claims concerning the validity of the rule. The Court will grant Plaintiffs’ motions for summary judgment, deny Defendants’ cross-motions, and vacate the rule