Filed Date: Feb. 13, 2025
Case Ongoing
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This case is one of several challenging the Trump administration’s authority to suspend congressionally appropriated federal funds pending a review of whether the spending aligns with the administration’s policy priorities. (To see the Clearinghouse's collection of legal challenges to spending freezes and cuts by the second Trump administration, click here.)
On January 20, 2025, President Trump signed Executive Orders 14151, 14154, 14168, and 14173, directing federal agencies to immediately pause the disbursement of congressionally appropriated funds. As a result, organizations and states that had been promised these funds were unable to access the allocated money.
On February 13, 2025, the Governor of Pennsylvania and several Pennsylvania state departments filed this lawsuit in the U.S. District Court for the Eastern District of Pennsylvania against the U.S. Department of the Interior, the U.S. Environmental Protection Agency, the U.S. Department of Energy, the U.S. Department of Transportation, the Office of Management and Budget, and their respective agency heads. The plaintiffs claimed that the defendants’ actions violated the Administrative Procedure Act, Take Care Clause, and Spending Clause. Judge Mitchell S. Goldberg presided over the case.
The plaintiffs alleged that the defendants unlawfully suspended or restricted access to billions in congressionally appropriated grant funds already committed to Pennsylvania. These included over $3 billion for abandoned mine land and waterway repairs, $76 million to plug oil and gas wells, $126 million for low-income utility assistance, $800 million for clean water infrastructure, $400 million for industrial emissions reduction, and tens of millions for rural electric service. Since January 27, 2025, over $3.1 billion for FY 2022–2026 and $2.69 billion for FY 2027–2037 had been frozen, jeopardizing at least $5.5 billion.
The plaintiffs argued that the freeze, based on vague executive orders and OMB directives, was unlawful because the agencies had no authority to withhold funds already appropriated and obligated, exceeded their statutory limits, and acted arbitrarily without clear standards or regard for Pennsylvania’s reliance interests. They further alleged violations of the Spending Clause and the President’s duty to “take Care that the laws be faithfully executed,” asserting that new conditions could not be imposed after the state accepted funds and that federal money could not be terminated for reasons not authorized by law or the funding agreements.
Represented by public counsel, the plaintiffs sought declaratory relief and injunctive relief to enjoin the federal agencies from freezing, pausing, conditioning, or otherwise interfering with the disbursement of any congressionally appropriated funds obligated to Pennsylvania.
Less than two weeks after filing this lawsuit, on February 24, Pennsylvania Governor Shapiro announced that all $2.1 billion in Congressionally-appropriated federal funding owed to the state (identified at the time of filing the lawsuit) had been unfrozen.
On August 13, 2025, the plaintiffs voluntarily dismissed the action without prejudice, stating, “all funding at issue in this lawsuit has been made available to Plaintiffs once again.”
Summary Authors
Lacie Melasi (2/22/2025)
Victoria Tan (8/15/2025)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69636221/parties/shapiro-v-us-department-of-the-interior/
Goldberg, Mitchell S. (Pennsylvania)
BOYER, JACOB B. (Pennsylvania)
FISCHER, MICHAEL J. (Pennsylvania)
KOVATIS, STEPHEN R. (Pennsylvania)
BERKEN, GREGORY BYRON (Pennsylvania)
See docket on RECAP: https://www.courtlistener.com/docket/69636221/shapiro-v-us-department-of-the-interior/
Last updated Aug. 19, 2025, 10:21 p.m.
State / Territory: Pennsylvania
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: Feb. 13, 2025
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
The Governor of Pennsylvania and several Pennsylvania state departments, including the Department of Environmental Protection, Department of Conservation and Natural Resources, Department of Transportation, and Department of Community and Economic Development
Plaintiff Type(s):
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
U.S. Department of the Interior (- United States (national) -), Federal
U.S. Environmental Protection Agency (- United States (national) -), Federal
U.S. Department of Energy (- United States (national) -), Federal
U.S. Department of Transportation (- United States (national) -), Federal
Office of Management and Budget (- United States (national) -), Federal
Defendant Type(s):
Case Details
Causes of Action:
Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.
Constitutional Clause(s):
Spending/Appropriations Clauses
Available Documents:
Outcome
Prevailing Party: None Yet / None
Nature of Relief:
Source of Relief:
Issues
Presidential/Gubernatorial Authority: