PHILADELPHIA – In a stunningly worded 40-page opinion released February 16, 2026, U.S. District Judge Cynthia Rufe ordered the Trump administration to immediately restore slavery-related exhibits removed from the President’s House site at Independence National Historical Park. The case, City of Philadelphia v. Burgum, marks a significant judicial intervention yet in the growing struggle over how American history is presented in public spaces.
Judge Rufe granted a preliminary injunction requiring the National Park Service (NPS) to reinstall all removed panels and video exhibits and prohibiting further changes without mutual written agreement between the City of Philadelphia and the federal government. The ruling came after the NPS removed 34 educational panels and deactivated videos discussing slavery at the site built atop the foundation of George Washington’s Philadelphia residence.
Image credit: Blogtrepreneur – CC BY 2.0, https://commons.wikimedia.org/w/index.php?curid=50979400
In language that was rhetorically striking, legally ambitious, and unusually direct in tone, Rufe compared the government’s actions to George Orwell’s 1984, warning against a regime where history can be “scraped clean and reinscribed.” She wrote that the government’s claim to erase or alter historical accounts at national monuments echoed Orwell’s dystopian vision. “The government here likewise asserts truth is no longer self-evident, but rather the property of the elected chief magistrate and his appointees and delegees,” the George W. Bush appointee wrote. “And why? Solely because, as Defendants state, it has the power.”
The President’s House site interprets the “paradox” of liberty and bondage at the nation’s founding. George Washington enslaved people both at this Philadelphia residence and at Mount Vernon, where exhibits, reconstructed enslaved quarters, and burial grounds acknowledge that history. In Philadelphia, the exhibits told the stories of nine enslaved Africans, including Oney Judge, who escaped in 1796 and later lived free in New Hampshire.
National Park Service logo [public domain
Rufe emphasized that Oney Judge’s story is central to the site’s inclusion in the Underground Railroad “Network to Freedom,” created under a 1998 federal law. Removing that interpretation, she wrote, undermines the very statutory basis for the site’s designation.
The removals followed President Donald Trump’s March 27, 2025, executive order, “Restoring Truth and Sanity to American History.” The order directed the Interior Department to eliminate displays that promote what it described as “corrosive ideology” and narratives portraying the United States as “inherently racist, sexist, oppressive, or otherwise irredeemably flawed.” It specifically referenced Independence National Historical Park, the Smithsonian American Art Museum, and the National Museum of African American History and Culture.
Trump’s order asserted that recent interpretive approaches deepen societal divides and foster “a sense of national shame,” calling instead for monuments to be “uplifting.” Critics, including preservation advocates, religious leaders, and historians, have argued that the directive amounts to an effort to whitewash history. Justice Department lawyers argued in court that the federal government has the right to express its preferred views on such matters.
Judge Rufe disagreed, not on free speech grounds, but on administrative law. Under the Administrative Procedure Act, agency action must not be arbitrary and capricious. The court found likely violations because NPS failed to consult the City of Philadelphia, as required by longstanding cooperative agreements dating to 1948; because the removal conflicted with statutory obligations governing the park; because it disregarded NPS’s own Foundation Document, which emphasizes the “Paradox of Freedom and Slavery”; and because it undermined the Underground Railroad Network to Freedom designation.
“An agency … cannot arbitrarily decide what is true, based on its own whims or the whims of the new leadership,” Rufe declared in her ruling, issued as the nation marked Washington’s birthday. Restoration of the exhibits, she added, does not infringe on federal free speech. “The government can convey a different message without restraint elsewhere if it so pleases, but it cannot do so to the President’s House until it follows the law and consults with the City.”
The decision arrives amid broader efforts to recast American history in public institutions. Late last year, reports emerged that exhibits related to slavery at multiple national parks were under review, including the removal of a Civil War–era photograph showing the scarred back of a formerly enslaved man, one of the most searing images of American bondage. “Pretending that the bad stuff never happened is not going to make it go away,” Alan Spears of the National Parks Conservation Association said in September of last year. “We need to be able to talk about these things if we’re going to have any hope of bringing people together.”
The panels removed in Philadelphia described the “intentional brutality” of slavery and its unparalleled cultural destruction. The devastation extended far beyond the American South. The transatlantic slave trade tore millions of Africans from their homelands, fracturing societies and religious traditions across West Africa.
Sacred lineages were broken; priesthoods decimated; ritual knowledge interrupted. Yet West African traditional religions survived and evolved in the Americas, shaping Vodou, Candomblé, Lucumí, and other diasporic traditions, as well as spiritual practices such as Hoodoo. The forced rupture severed communities from their spiritual landscape, ancestral burial grounds, and sacred ecologies. The cultural erasure was not incidental to slavery; it was one of its engines.
The Equal Justice Initiative has documented how religious narratives were manipulated to sustain the institution. In its report Slavery in America, EJI notes that when slavery began in the 17th century, British law forbade the enslavement of Christians. Enslavers feared that if Africans converted, they might claim freedom, a fear realized in 1656 when Elizabeth Key successfully sued for emancipation on the basis of her Christianity. To preserve slavery, religious doctrine was reshaped. In 1664–1665, minister Richard Baxter argued that slavery was a righteous institution that could “save African souls” without requiring their freedom. Colonial laws soon followed, declaring that Christian baptism did not exempt enslaved people from bondage. As EJI observes, these laws allowed white evangelicals to convert Black people “without the risk of forced emancipation,” while further restricting Black religious practice and interracial worship.
Efforts to sanitize slavery did not end with emancipation. EJI documents that in 1996, an Alabama state senator described slavery as a “family institution” and “civilizing influence,” claiming enslaved people were “most grateful” for Christianity. Confederate monuments erected decades later echoed similar distortions.
Against this long arc of denial and revisionism, the Philadelphia ruling stands as a reminder that history is not infinitely malleable. Courts may not decide moral truth, but they can enforce statutory guardrails. By grounding her decision in cooperative federalism and administrative law rather than cultural rhetoric alone, Judge Rufe signaled that even interpretive spaces must operate within legal limits.
The case is likely headed for appeal. But for now, the panels telling the documented history of slavery, and those who survived it, at the nation’s founding must return.
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