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 27, 2025, an Office of Management and Budget (OMB) memorandum directed federal agencies to temporarily pause activity related to obligation or disbursement of Federal financial assistance, and funds for other activities implicated by executive orders, including financial assistance for foreign aid, nongovernmental organizations, DEI, “woke gender ideology”, and the Green New Deal. The memorandum stated the pause was to ensure federal funding prioritizes a “safer America” and to “eliminat[e] the financial burden of inflation for citizens” while expunging wasteful use of “Federal resources to advance Marxist equity, transgenderism, and green new deal social engineering policies.”
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 the President of the United States, the Office of Management and Budget (OMB), and several executive agencies under the Administrative Procedure Act (APA), 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 OMB 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. 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The Administration rescinded the freeze order on January 29, 2025, after a federal judge in a different case issued an administrative stay on January 28, preventing the funding freeze from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, 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 (TRO), operative until the Court ruled on Plaintiffs’ motion for a Preliminary Injunction (PI). 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 likely contrary to law, violated the APA, principles of separation of powers, and was contrary to congressional intent and directive. The order also stated that the Defendants have not followed the procedure under the Impoundment Control Act for the purported pause. 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 the jurisdiction of reviewing courts. 2025 WL 357368.
The TRO prohibited Defendants from obstructing the federal government’s compliance with federal financial awards or obligations to Plaintiff states. It further banned Defendants from interfering with Plaintiff states’ access to such awards and funding disbursement.
On February 3, 2025, 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, Plaintiffs filed their motion for a PI and an emergency motion to enforce the TRO. In the emergency motion to enforce the TRO, the Plaintiffs alleged that the Government was taking the position that funds under the Infrastructure and Jobs Act and the Inflation Reduction Act were excluded from the TRO, and that they had 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." 2025 WL 440873
The court entered further injunctive relief, requiring Defendants to restore frozen funding during the pendency of the TRO until the Court hears and decides the PI 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.
On February 10, the Defendants filed a notice of appeal and a motion to stay the TRO pending appeal, which was denied on February 12. On the same day, the Defendants filed their response to the motion for PI.
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 Defendants then voluntarily withdrew their appeal.
Back in the district court, a hearing on the PI motion was held on February 21, 2025, and the States filed a second motion to enforce on February 28, suggesting that Defendants were not complying. On March 6, the court granted the PI and denied the motion to enforce as moot. 769 F.Supp.3d 119.
On March 10, Defendants appealed the order and PI to the First Circuit (under appeal number 25-1236). Plaintiff-Appellees filed their response on March 17, and Defendant-Appellants filed their reply on March 20.
Plaintiffs filed a motion for enforcement of the PI on March 24, arguing that millions of dollars in obligated FEMA (Federal Emergency Management) awards remained frozen despite the injunction. The motion asked the court to order FEMA to cease freezing obligated funds and circulate notice of the PI to the agency's leadership and staff. Defendants responded to the enforcement motion on March 27. On the same day, the First Circuit denied Defendant-Appellants' motion for a stay pending the appeal of the PI.
The District Court granted the enforcement motion on April 4, ordering FEMA to comply with the terms of the PI. 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 PI 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 PI and enforcement order on April 7 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 did not require the District Court to review individual contractual obligations or provisions between the Plaintiff states and FEMA.
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 appeal before the First Circuit is scheduled for oral hearing on November 12, 2025.
The case is ongoing.
Summary Authors
Meredith Ulle (2/22/2025)
Muhammad Hammad Amin (10/23/2025)
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
Arrowsmith, Nathan T.
Arslanian, Vanessa
Armstrong, Anne
Attorney, Miriam Becker-Cohen,
See docket on RECAP: https://www.courtlistener.com/docket/69653831/state-of-new-york-v-trump/
Last updated Nov. 11, 2025, 3:45 a.m.
State / Territory:
Case Type(s):
Presidential/Gubernatorial Authority
Special Collection(s):
Trump Administration 2.0: Challenges to the Government
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:
Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.
Declaratory Judgment Act, 28 U.S.C. § 2201
Ex Parte Young (Federal) or Bivens
Constitutional Clause(s):
Spending/Appropriations Clauses
Other Dockets:
District of Rhode Island 1:25-cv-00039
U.S. Court of Appeals for the First Circuit 25-01138
U.S. Court of Appeals for the First Circuit 25-01236
U.S. Court of Appeals for the First Circuit 25-01413
Available Documents:
Outcome
Prevailing Party: None Yet / None
Relief Granted:
Preliminary injunction / Temp. restraining order
Source of Relief:
Content of Injunction:
Issues
General/Misc.:
Presidential/Gubernatorial Authority: