I'm not an administrative law geek but I suspect there's a process of appeal within the structure of the DOE. Charlotte will certainly pursue that line of defense while also litigating in the courts. I'm also reasonably confident that this decision of the DOE will be stayed during the process of litigation. In other words, the law school won't shut down as of January 1. Nonetheless, the short-term effect of this decision, even if stayed, can be expected to have a substantial impact on the new class of law students that Charlotte would expect to enroll in the fall of 2017.
(For a few of my earlier comments on the effects of federal subsidies on the cost of higher education go here and on the world of for-profit higher education in general go here.)