Filed Date: March 13, 2025
Case Ongoing
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On March 13, 2025, Butterbee Farm, Cultivate KC, Faith in Place, GreenLatinos, Hendrix Farm, One Acre Farm, Red Fire Farm, and Two Boots Farm (Plaintiffs) filed a complaint in the United States District Court for the District of Columbia against the United States Department of Agriculture, the Office of Management and Budget (OMB), and Donald J. Trump in his official capacity as President of the United States of America.
Plaintiffs sought to compel the United States Department of Agriculture (USDA) to lift an alleged unlawful and indefinite freeze of Congressionally appropriated funds for farmers, non-profit organizations, and other USDA grantees. The plaintiffs’ claims were based on the separation of powers, the Take Care Clause, and the Administrative Procedure Act (APA).
The plaintiffs had received federal USDA grants under programs such as the Inflation Reduction Act (IRA) and acted in reliance on these grants. On President Trump's first day in office, however, he released the Unleashing American Energy Executive Order (EO 14154), which paused IRA grant disbursements until the administration could review grants for consistency with the President's policy preferences. Following the EO, the Office of Management and Budget ordered USDA to halt disbursement of funds, including to existing grantees performing projects for which USDA had already obligated funds. USDA complied by cutting off IRA grant recipients’ access to payment portals, refusing to process invoices, canceling check-in meetings, and failing to respond to requests for clarification from grantees.
The plaintiffs argued that the defendants' actions violated the Constitution and the APA. Specifically, the plaintiffs alleged that 1) the EO exceeded presidential power and usurped legislative authority in violation of the separation of powers; 2) By freezing funding appropriated by Congress without regard to statutes, regulations, and terms governing that funding, the defendants acted contrary to the Executive’s duty to take care that the laws be faithfully executed; 3) The defendants’ actions constituted the unlawful impoundment of appropriated funds in violation of the Impoundment Control Act and the APA; and 4) The defendants’ refusal to disburse obligated funds was arbitrary and capricious in violation of the APA.
The plaintiffs sought declaratory relief and an order vacating the agency actions implementing the freeze, and preliminary and permanent injunctions preventing the defendants from continuing the freeze and compelling them to release the frozen funds.
The plaintiffs were represented by Earthjustice, and the case was assigned to District Judge Rudolph Contreras.
The plaintiffs filed an amended complaint on May 19, which removed plaintiffs Butterbee Farm and One Acre Farm, adding instead plaintiffs Foodshed Alliance and Hope for Small Farm Sustainability. The amended complaint also removed OMB and its director from the list of defendants. The new complaint added details on how the defendants' actions caused harm to the plaintiffs and were unlawful under existing regulations. While adding no new legal claims, the amended complaint did request different relief. Due to a preliminary injunction issued in a different case, Woonasquatucket River Watershed Council v. Department of Agriculture, that also challenged the freezing of USDA grants, "USDA ha[d] resumed processing invoices and advance requests for IRA grant recipients, including Plaintiffs." Therefore, the plaintiffs no longer requested a preliminary injunction but rather asked the court for declaratory and permanent injunctive relief preventing the defendants from freezing the grants in the future.
On June 16, the parties proposed a briefing schedule on the parties' cross-motions for summary judgment, with the plaintiffs filing their motion for summary judgment on July 18.
This case is ongoing.
Summary Authors
Oliver Farnum (4/9/2025)
Jeremiah Price (6/17/2025)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69733481/parties/butterbee-farm-v-united-states-department-of-agriculture/
Contreras, Rudolph (District of Columbia)
Apfel, Carrie F. (District of Columbia)
Prothero, Mary (District of Columbia)
Becker-Cohen, Miriam (District of Columbia)
Gorod, Brianne Jenna (District of Columbia)
See docket on RECAP: https://www.courtlistener.com/docket/69733481/butterbee-farm-v-united-states-department-of-agriculture/
Last updated Aug. 23, 2025, 10:21 p.m.
State / Territory: District of Columbia
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: March 13, 2025
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
Plaintiffs are farmers and non-profit organizations that received USDA grants.
Plaintiff Type(s):
Non-profit NON-religious organization
Attorney Organizations:
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
United States Department of Agriculture (Washington, D.C., District of Columbia), Federal
Donald J. Trump (in his official capacity) (Washington, D.C., District of Columbia), Federal
Case Details
Causes of Action:
Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.
Constitutional Clause(s):
Available Documents:
Outcome
Prevailing Party: None Yet / None
Nature of Relief:
Source of Relief:
Issues
General/Misc.:
Presidential/Gubernatorial Authority: