Mackinac Center for Pub. Pol'y v. U.S. Dep't of Educ.

── Mackinac Center for Pub. Pol'y v. U.S. Dep't of Educ. ── Court: Court of Appeals for the Sixth Circuit Date: May 08, 2026 Category: General RECOMMENDED FOR PUBLICATION Pursuant to Sixth Circuit I.O.P. 32.1(b) File Name: 26a0137p.06 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT ┐ MACKINAC CENTER FOR PUBLIC POLICY, │ Plaintiff-Appellant, │ > No. 24-1784 │ v. │ │ UNITED STATES DEPARTMENT OF EDUCATION; LINDA │ MCMAHON, Secretary of U.S. Department of │ Education; JAMES BERGERON, Chief Operating Officer │ of Federal Student Aid, U.S. Department of Education │ Defendants-Appellees. │ ┘ Appeal from the United States District Court for the Eastern District of Michigan at Bay City. No. 1:23-cv-10795—Thomas L. Ludington, District Judge. Argued: February 5, 2026 Decided and Filed: May 8, 2026 Before: BOGGS, NALBANDIAN, and MATHIS, Circuit Judges. _________________ COUNSEL ARGUED: Russell G. Ryan, NEW CIVIL LIBERTIES ALLIANCE, Arlington, Virginia, for Appellant. Sarah N. Smith, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellees. ON BRIEF: Russell G. Ryan, Daniel Kelly, NEW CIVIL LIBERTIES ALLIANCE, Arlington, Virginia, for Appellant. Sarah N. Smith, Michael S. Raab, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellees. MATHIS, J., delivered the opinion of the court in which NALBANDIAN, J., concurred. BOGGS, J., concurred in the judgment only.  No. 24-1784 Mackinac Center for Public Policy v. U.S. Dep’t of Educ. Page 2 _________________ OPINION _________________ MATHIS, Circuit Judge. The COVID-19 pandemic transformed nearly every aspect of daily life. State and local governments issued stay-at-home orders. Businesses closed their doors. Social distancing became the norm. And the medical system was pushed to its limits. The executive and legislative branches reacted swiftly to mitigate the effects of the pandemic on the American people. Some of these actions impacted the federal student-loan system. From 2020 to 2023, the U.S. Department of Education repeatedly suspended student-loan payments and froze interest for all borrowers. For those enrolled in student-loan-forgiveness programs, the Department of Education counted nonpayments during the suspensions toward the monthly payments required for total loan forgiveness. And in June 2023, the Department of Education instituted a twelve-month on-ramp to repayment running from October 1, 2023, to September 30, 2024. During this period, borrowers needed to make their loan payments and interest accrued on their loans, but the interest did not capitalize at the end of the twelve-month period. Mackinac Center for Public Policy believes that the Department of Education acted beyond its authority in taking such actions. So it sued to have these administrative actions set aside, seeking to prevent the Department of Education from counting nonpayments during the repayment-and-interest pause toward student-loan forgiveness. Because Mackinac failed to establish Article III standing, the district court dismissed its complaint for