Filed Date: Jan. 28, 2025
Case Ongoing
Clearinghouse coding complete
This case challenged the Trump Administration's authority to suspend congressionally-appropriated federal financial assistance pending a review to ensure that the spending accords with Administration priorities. On January 28, 2025, twenty-two states and the District of Columbia filed this lawsuit in the U.S. District Court for the District of Rhode Island. The plaintiffs sued President Trump, the Office of Management and Budget, and a number of executive agencies under the Administrative Procedure Act, Declaratory Judgment Act, and Ex Parte Young. Represented by the Attorneys General of each plaintiff state and D.C., the plaintiffs alleged that a January 27, 2025 directive from the Office of Management and Budget temporarily suspending nearly all federal financial assistance programs violated the APA and several Constitutional provisions, including the Spending and Appropriations Clauses, the Presentment Clause, the Take Care Clause, and separation of powers principles. The plaintiffs sought preliminary and permanent injunctions and declaratory relief. The case was assigned to Chief Judge John J. McConnell.
The Administration rescinded the freeze order on January 29, 2025 after a federal judge in a different case issued an administrative stay on January 28 preventing the funding freeze from going into effect. At a hearing before Judge McConnell on January 29, the government argued that the issue was moot. At the hearing, the plaintiffs' lawyers displayed a social media post from White House press secretary Karoline Leavitt stating the Administration’s continued commitment to restricting federal funding despite the rescission of the OMB Directive.
On January 31, 2025, Judge McConnell issued a temporary restraining order, operative until the Court ruled on the plaintiffs’ anticipated motion for a preliminary injunction. The Court held that the States were likely to succeed on the merits of their claims. The order also stated that unilateral suspension of federal payments was contrary to law, violated the APA and separation of powers, and was contrary to congressional intent and directive. Moreover, the Court found that the rescission of the OMB Directive was in name only and was possibly done for the sole purpose of defeating jurisdiction of reviewing courts. 2025 WL 357368.
The TRO prohibited the defendants from obstructing the federal government’s compliance with federal financial awards or obligations to the plaintiff states. It further banned the defendants from interfering with the plaintiff states’ access to such awards and funding disbursement.
On February 3, 2025, the defendants filed a notice of compliance with the TRO, certifying that they had provided written notice of the TRO to the named defendant agencies with instructions to disseminate the notice to employees, contractors, and grantees of those agencies.
On February 7, 2025, the plaintiffs filed their motion for a preliminary injunction. The defendants filed their response on February 12.
The same day they filed their preliminary injunction motion, the States filed an emergency motion to enforce the TRO along with a motion for a preliminary injunction. They alleged that the Government was taking the position funds under the Infrastructure and Jobs Act, and the Inflation Reduction Act, were excluded from the TRO, and had also frozen other expenditures, including to Head Start recipients and HIV prevention programs. The States asked for immediate relief--which the district court granted on February 10. The Court noted:
The States have presented evidence in this motion that the Defendants in some cases have continued to improperly freeze federal funds and refused to resume disbursement of appropriated federal funds. The Defendants now plea that they are just trying to root out fraud. But the freezes in effect now were a result of the broad categorical order, not a specific finding of possible fraud. The broad categorical and sweeping freeze of federal funds is, as the Court found, likely unconstitutional and has caused and continues to cause irreparable harm to a vast portion of this country. These pauses in funding violate the plain text of the TRO.
The Court entered further injunctive relief, requiring the defendants to restore frozen funding during the pendency of the TRO until the Court hears and decides the Preliminary Injunction request, and to "immediately end any federal funding pause", "immediately take every step necessary to effectuate the TRO, including clearing any administrative, operational, or technical hurdles to implementation." It clarified that the "TRO requirements include any pause or freeze included in the Unleashing Guidance," and specified that the TRO covered OMB directives, funding of institutes and other agencies (for example the National Institute for Health), and reached federal funds appropriated in the Inflation Reduction Act and the Infrastructure Improvement and Jobs Act. 2025 WL 440873.
The United States immediately appealed this order and also the underlying TRO (under appeal number 25-1138) and sought a stay of the district court's order; the appellate court declined to enter an immediate stay on February 11, 2025, but said it would continue to consider whether to grant a stay pending appeal after further briefing. 2025 WL 455494. The U.S. then voluntarily withdrew its appeal.
A hearing on the preliminary injunction motion was held on February 21, 2025, and the states filed a second motion to enforce on February 28, suggesting that the defendants were not complying. On March 6, the court granted the preliminary injunction, and denied the motion to enforce as moot.
On March 10, the defendants appealed the order and preliminary injunction to the First Circuit (under appeal number 25-1236). The plaintiff-appellees filed their response on March 17, and the defendant-appellants filed their reply on March 20.
The plaintiffs filed a motion for enforcement of the preliminary injunction on March 24, arguing that millions of dollars in obligated FEMA awards remained frozen despite the injunction. The motion asked the court to order FEMA to cease freezing obligated funds and circulate notice of the preliminary injunction to the agency's leadership and staff. The defendants responded to the enforcement motion on March 27.
Also on March 27, the First Circuit denied the defendant-appellants' motion for a stay pending the appeal of the preliminary injunction.
The District Court granted the enforcement motion on April 4, ordering FEMA to comply with the terms of the preliminary injunction. The defendants filed an emergency motion for reconsideration of the enforcement order the next day, citing the Supreme Court's April 4 decision in Department of Education v. California issuing a stay of a preliminary injunction and indicating that suits involving contracts with the federal government must be brought in the U.S. Court of Federal Claims. Judge McConnell issued a temporary stay of the preliminary injunction and enforcement order on April 7 in order to adequately address the reconsideration motion. After receiving briefing from all parties, the Court denied the motion for reconsideration on April 14, distinguishing this case from Department of Education v. California because the funding freeze here was categorical and thus didn't require the district court to review individual contractual obligations or provisions between the plaintiff states and FEMA.
The defendants appealed the April 4 enforcement order and the April 14 denial of their reconsideration motion to the First Circuit on April 28 (appeal no. 25-1413). On May 5 the Court of Appeals granted an unopposed motion to consolidate the two pending appeals (25-1236 and 25-1413) and ordered the defendant-appellants to file their brief by May 27, 2025.
The case is ongoing.
Summary Authors
Meredith Ulle (2/22/2025)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69653831/parties/state-of-new-york-v-trump/
Anton, Jason David (Rhode Island)
Arrowsmith, Nathan T. (Rhode Island)
Arslanian, Vanessa A. (Rhode Island)
Armstrong, Anne
Attorney, Miriam Becker-Cohen,
Anton, Jason David (Rhode Island)
Arrowsmith, Nathan T. (Rhode Island)
Arslanian, Vanessa A. (Rhode Island)
Banghart-Linn, Linus (Rhode Island)
Beatty-Walters, Christina L. (Rhode Island)
Cahn, Amy Laura (Rhode Island)
Chuang, Christine (Rhode Island)
Dirks, Katherine B. (Rhode Island)
Duraiswamy, Shankar (Rhode Island)
Faherty, Colleen K. (Rhode Island)
Feigenbaum, Jeremy (Rhode Island)
Fernandes, Kalikoonalani Diara (Rhode Island)
Giarrano, Leonard Giarrano (Rhode Island)
Giovanatti, Neil (Rhode Island)
Green, Nicholas R. (Rhode Island)
Grube, Mark Stephen (Rhode Island)
Hughes, Andrew R.W. (Rhode Island)
Hyman, Nathaniel James (Rhode Island)
Jonas-Day, Julia (Rhode Island)
Kassab, Vanessa L. (Rhode Island)
Kirschner, Adam D. (Rhode Island)
Kissel, Christopher J. (Rhode Island)
Koch, Robert A. (Rhode Island)
Kramer, Elizabeth (Rhode Island)
Lacedonia, Jill (Rhode Island)
Logan, Marie E. (Rhode Island)
Lumelsky, Anna Esther (Rhode Island)
Mayo, Steven Travis (Rhode Island)
McCombs, Theodore (Rhode Island)
Mendrala, Andrew C. (Rhode Island)
Mosteller, Daniel Paul (Rhode Island)
Munson, Carly J. (Rhode Island)
Muqaddam, Rabia (Rhode Island)
Myers, Michael J. (Rhode Island)
Pappavaselio, Chris (Rhode Island)
Payne, Taylor Allen (Rhode Island)
Rose, Jonathan T. (Rhode Island)
Sabatini, Kathryn M. (Rhode Island)
Skold, Michael Kenneth (Rhode Island)
Stern, Heidi Parry (Rhode Island)
Stevenson, Shannon Wells (Rhode Island)
Sugarman, Kenneth J. (Rhode Island)
Thomas-Jensen, Molly (Rhode Island)
Tipton, Laura Crittenden (Rhode Island)
See docket on RECAP: https://www.courtlistener.com/docket/69653831/state-of-new-york-v-trump/
Last updated Aug. 22, 2025, 3:32 a.m.
State / Territory: Rhode Island
Case Type(s):
Presidential/Gubernatorial Authority
Special Collection(s):
Trump Administration 2.0: Challenges to the Government
Trump Administration 2.0: Challenges to the Government (Spending Freezes/Cuts)
Key Dates
Filing Date: Jan. 28, 2025
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
Plaintiffs are the states of New York, California, Illinois, Rhode Island, New Jersey, Massachusetts, Arizona, Colorado, Connecticut, Delaware, Hawai'i, Maine, Maryland, Michigan, Minnesota, Nevada, North Carolina, New Mexico, Oregon, Vermont, Washington, Wisconsin, and the District of Columbia.
Plaintiff Type(s):
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
President Donald J. Trump (District of Columbia), Federal
Office of Management and Budget (District of Columbia), Federal
U.S. Department of the Treasury (District of Columbia), Federal
U.S. Department of Health & Human Services (District of Columbia), Federal
U.S. Department of Education (District of Columbia), Federal
U.S. Department of Homeland Security (District of Columbia), Federal
U.S. Department of Transportation (District of Columbia), Federal
U.S. Department of Labor (District of Columbia), Federal
U.S. Department of Energy (District of Columbia), Federal
U.S. Environmental Protection Agency (District of Columbia), Federal
U.S. Department of Justice (District of Columbia), Federal
U.S. Department of Homeland Security (District of Columbia), Federal
National Science Foundation (District of Columbia), Federal
National Aeronautics and Space Administration (- United States (national) -), Federal
Corporation for National and Community Service (- United States (national) -), Federal
U.S. Agency for International Development (- United States (national) -), Federal
U.S. Department of Agriculture (- United States (national) -), Federal
U.S. Department of Commerce (- United States (national) -), Federal
U.S. Department of Defense (- United States (national) -), Federal
U.S. Department of Housing and Urban Development (- United States (national) -), Federal
U.S. Department of State (- United States (national) -), Federal
U.S. Department of the Interior (- United States (national) -), Federal
U.S. Department of Veterans Affairs (- United States (national) -), Federal
U.S. Small Business Administration (- United States (national) -), Federal
U.S. Social Security Administration (- United States (national) -), Federal
Defendant Type(s):
Case Details
Causes of Action:
Ex Parte Young (Federal) or Bivens
Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.
Declaratory Judgment Act, 28 U.S.C. § 2201
Constitutional Clause(s):
Spending/Appropriations Clauses
Available Documents:
Outcome
Prevailing Party: None Yet / None
Nature of Relief:
Preliminary injunction / Temp. restraining order
Source of Relief:
Content of Injunction:
Order Duration: 2025 - None
Issues
General/Misc.:
Presidential/Gubernatorial Authority: