BJA Will Pay 22 Jurisdictions to Erase Federal Judges From Their Own Public Records. The Eligibility Test Isn't Who You Are — It's Which Database You Run.
September 25, 2026 · 7 min read
Granted Research Team · Editorial policy
Most federal grant programs sort applicants by organization type. The FY 2026 Daniel Anderl Judicial Security and Privacy Program sorts them by asset — specifically, by whether the applicant operates a database. If you don't run one containing what the statute calls "covered information," you are not eligible, and no amount of partnership, mission alignment, or letters of support changes that.
The solicitation is O-BJA-2026-172661, posted by the Bureau of Justice Assistance on July 23, 2026, with deadlines extended on August 20. It carries up to $6,526,269 across 22 anticipated awards, and it closes in Grants.gov on October 15, 2026 at 11:59 p.m. Eastern and in JustGrants on October 22, 2026 at 8:59 p.m. Eastern.
The money splits cleanly into two categories, and the arithmetic tells you what BJA expects:
- Category 1 — Program Implementation: 15 awards, up to $200,000 each. That's $3.0 million.
- Category 2 — Program Enhancement: 7 awards, up to $500,000 each. That's $3.5 million.
Total: $6.5 million, with a 36-month performance period beginning October 1, 2026, no cost-sharing requirement, and a hard limit of one application to one category per applicant.
The Mandatory Eligibility Requirement Is the Whole Story
Eligible entity types read broadly at first: state, county, city or township, special district, and federally recognized tribal governments, plus other units of local government and agencies of any of the above. Then the NOFO adds this:
"In addition to being one of the entity types listed above, applicants must operate a state or local database or registry that contains covered information as defined by the Daniel Anderl Judicial Security and Privacy Act of 2022."
BJA cites the source — Section 5934(c)(1)(A)(ii) — which means this is not an agency preference BJA could waive. It is statutory. And it collapses the applicant pool in a way worth spelling out, because the gate excludes several categories of organization that would otherwise look like natural fits:
Nonprofits are not eligible at any tier as applicants. Not judicial-security advocacy organizations, not privacy nonprofits, not court-adjacent associations. The entity-type list contains no nonprofit category at all — unusual even among government-facing BJA programs.
Courts, as such, are a question mark. A court system that operates its own case-management registry containing home addresses and dates of birth likely satisfies the test. A court that relies on a county clerk's records system does not operate that system, and the clerk's office would be the eligible applicant.
The eligible applicant may not be the agency with the judicial-security mandate. The offices that actually hold covered information are the mundane ones: county recorders of deeds, motor vehicle departments, voter registration offices, property assessors, and court clerks. The NOFO's own project-design questions name exactly these systems — "voter registration, Department of Motor Vehicles, property records, court records" — which tells you who BJA thinks is applying.
The workaround is structural, and the NOFO states it explicitly: an entity may be proposed as a subrecipient in more than one application. A statewide judicial-security office that cannot pass the database test can be the subrecipient doing the work across several county applications. A redaction vendor can appear in all 22. Only the prime applicant has to hold the database.
The MOU Is a Required Attachment, Not a Nice-to-Have
The application contents list marks Memorandum of Understanding as Required — the same status as the SF-424, the proposal narrative, and the budget. An MOU or letter of intent must be attached between the applicant and each project partner, submitted as one consolidated attachment.
BJA does allow unsigned drafts, with a condition: you must include a cover page explaining why each one is unsigned. That is a genuine accommodation and worth using. It is also a reviewer signal. A package of unsigned drafts with a cover page saying "awaiting county counsel review" reads very differently from one that says "partner has not yet been contacted."
Twenty days out, the practical sequencing is: identify every agency in your jurisdiction that holds covered information, get an intent letter from each, and attach what you have. An application with three signed MOUs and two annotated drafts beats an application with zero.
What "Covered Information" Actually Covers
The statutory definition is broader than the usual PII list, and the last three items are the ones that make this a security program rather than a privacy program:
Home addresses including secondary residences; home or personal mobile phone numbers; personal email; Social Security or driver's license number; bank, credit, or debit card information; license plate numbers or other unique vehicle identifiers; the identification of children under 18; full date of birth; school or day care attendance information, including schedules and routes taken to and from; and employment location information, including schedules and routes taken to and from the employer.
The protected class — "at-risk individuals" — is equally broad: federal judges, including senior, recalled, and retired judges; their spouses, parents, siblings, and children; anyone to whom a judge stands in loco parentis; and any individual living in the household.
Programs must operate on a request basis. Participation is voluntary, judges must affirmatively ask, and the NOFO directs applicants to build a standardized request form, outreach and notification procedures, defined response timeframes, and — critically — confidentiality controls so the request process doesn't itself identify which judges sought protection.
The Data Broker Clause Cuts Both Ways
Section 5934(d) makes it unlawful for a data broker to knowingly sell, license, trade, transfer, or purchase covered information about an at-risk individual, and bars any person or business from publicly posting it online once a written request has been made.
For applicants, that produces a precise budget rule, stated twice in the NOFO:
- Grant funds may pay third-party vendors to redact or remove covered information from public records — expressly authorized under Section 5934(c)(2)(A).
- Grant funds may not be used to purchase covered information from data brokers.
The distinction matters operationally, because the standard commercial approach to judicial de-listing involves buying your own exposure report first to find out where the data sits. Under this program, you can pay a contractor to remove records; you cannot pay one to sell you the inventory. Recipients also have to ensure contractors and subrecipients comply, which means flow-down language in every subaward.
The project-design section pushes further, asking applicants what steps they will take "to protect covered information from third-party commercial data aggregators that scrape, purchase, and resell judicial information." That is the honest hard problem: a county can scrub its own records and the data is still resident in a hundred downstream brokers. Strong applications will address persistence — the NOFO asks specifically about procedures for routine database updates, safeguards during system migrations, controls on interagency data sharing, and measures to prevent human error, all aimed at the failure mode where deleted records reappear on the next sync.
The Comptroller General Report Is an Unusual Deliverable
Section 5934(c)(3)(B) requires states and local governments receiving these funds to report annually to the Comptroller General of the United States. BJA will collect the data, and the required contents are specific:
- Where the judges' covered information was found.
- Any new types of personal data found to be used to identify threatened judges — the NOFO names prior home addresses, employers, and institutional affiliations such as nonprofit board memberships.
- Any other novel data types discovered that could locate or identify at-risk individuals.
Read that as what it is: a federal threat-intelligence collection requirement embedded in a local grant. Recipients are not just redacting; they are documenting the discovery surface. Applicants should build the records infrastructure for this from day one, because reconstructing "where we found it" 11 months into year one is not feasible.
Scoring and the Notification-Date Artifact
The 15-page, double-spaced narrative is scored: Description of the Need 5%, Project Goals and Objectives 15%, Project Design and Implementation 40%, Capabilities and Competencies 25%, Budget 15%.
Forty percent on design with only 5% on need is a clear instruction. Do not spend four pages establishing that judges face threats — BJA wrote the statute's premise into the NOFO. Spend them on interagency mechanics: which specific agencies are engaged, what formal agreements exist, how county and municipal systems integrate, how you balance privacy protection against public interest in records access, and what steps centralize data coordination.
One artifact deserves a flag. The NOFO's Key Dates table lists an Anticipated Notification Date of "By September 30, 2026" — five days from now, and three weeks before the JustGrants deadline it also lists. That is a leftover from the pre-extension schedule, not a signal that decisions are made. Applicants should assume notification slides well into FY 2027 and budget the October 1, 2026 project start date as nominal. If your budget assumes staff on payroll in October, rebuild it with a realistic ramp.
The program also carries BJA's standard FY 2026 conditions: agency funding priorities that include support for law enforcement operations "including immigration law enforcement operations," and an out-of-scope clause covering any activity that impedes enforcement of federal immigration law, including failure to comply with 8 U.S.C. § 1373 — the same architecture running through the ANGEL solicitation and the wider BJA consolidation underway for FY 2027.
At $200,000 across 36 months, Category 1 funds roughly $5,500 a month — one part-time records analyst plus vendor fees, not a program office. Twenty-two awards nationally against thousands of jurisdictions holding federal judges' records means this is a demonstration program, and the applications that win will be the ones that read like a replicable protocol rather than a one-county cleanup. Figuring out which federal programs your organization can actually pass the eligibility gate on, before you spend three weeks writing, is the work Granted is built for.