Case: State of California v. Trump
1:25-cv-10810 | U.S. District Court for the District of Massachusetts
Filed Date: April 3, 2025
Case Ongoing
Clearinghouse coding complete
Case Summary
This case challenged President Trump's March 25, 2025, Executive Order 14248, which imposed various requirements on federal elections.
On April 3, 2025, nineteen states filed this lawsuit in the United States District Court for the District of Massachusetts, naming the President, the U.S. Attorney General, the U.S. Election Assistance Commission (EAC) and its director and commissioners, and the Secretary of Defense as Defendants. Plaintiffs challenged multiple sections of the Executive Order 14248, including its requirements that (1) the EAC demand documentary proof of citizenship and record such information, (2) the heads of federal voter registration agencies assess citizenship prior to providing registration forms, (3) the Secretary of Defense ask for proof of citizenship in the Federal Post Card Application, (4) the Attorney General take action against states that counted absentee ballots received after Election Day, and (5) federal funding be conditioned upon compliance with the EO.
The plaintiffs alleged that by purporting to impose election rules on the states, the President exceeded his constitutional powers and unlawfully infringed on congressional and state authority, thereby violating the Separation of Powers, the Administrative Procedure Act, the National Voter Registration Act (NVRA), and the Uniformed and Overseas Citizens Absentee Voting Act (UOCAVA). Represented by their respective attorneys general, the plaintiffs sought declaratory and injunctive relief, as well as attorney fees.
The case was assigned to District Judge Denise J. Casper.
On April 23, the defendants moved to transfer and consolidate this case with a case in the District Court for the District of Columbia, League of United Latin American Citizens v. Executive Office of the President, which also challenged the EO. Judge Casper denied the motion on May 9, finding that transfer was not in the interests of justice in this case, given that the plaintiffs here were states, not private parties, and this case challenged different sections of the EO from those challenged in the D.D.C. case.
On May 5, the plaintiffs moved for a preliminary injunction. The court granted the motion on June 13, finding that the challenged sections were ripe for review since they either imposed deadlines or clearly laid out actions that the defendants were required to take. Turning to the merits, the court found that the President lacked the authority to take the actions challenged, since in federal statutes such as the NVRA, the Help America Vote Act (HAVA), and the UOCAVA, Congress set requirements for federal elections that did not include those required by the EO. Finally, the court found that Congress had never endorsed the EO's interpretation regarding absentee and mail-in ballots in its various Election Day statutes and that the EO could not impose conditions on formula grants since the Constitution "vests exclusive power in Congress to impose conditions on federal grants." Therefore, the court enjoined the defendants from implementing any of the challenged sections of the EO. 2025 WL 1667949.
Also on June 13, the defendants filed a motion to dismiss, arguing that the plaintiffs either lacked standing (since they were challenging actions that allegedly did not affect them) or were bringing claims that were not ripe (since they were bringing claims challenging actions that had not yet occurred, and which still needed to go through additional legal and policy processes). The defendants also argued that the plaintiffs failed to state a claim on the merits because the EAC is an Executive Agency, meaning that the president has supervisory authority over it under the Constitution.
On July 3, the defendants filed a motion to modify the preliminary injunction. Pointing to the Supreme Court's recent decision in CASA Inc. v. Trump, in which the Supreme Court held that federal courts lacked power to issue injunctions that provide relief to individuals who are not parties to a case, the defendants argued that because "this Court's preliminary injunction prohibiting Defendants from implementing Executive Order 14248's section 2(d) is broader than necessary to provide complete relief to the Plaintiffs in this case, the Court should grant this motion and modify its injunction concerning section 2(d) to the Plaintiffs." The court granted the request on July 18, modifying its preliminary injunction concerning Section 2(d) to only apply to the plaintiff states.
On September 17, Judge Casper denied defendants' June 13 motion to dismiss. For reasons similar to those stated in her preliminary injunction ruling, Judge Casper held that plaintiffs had standing because implementation of the EO would result in "burdens" on plaintiffs and plaintiffs' claims were sufficiently ripe. Judge Casper also found that, as stated in her preliminary injunction ruling, plaintiffs not only stated a plausible claim for relief, but were likely to succeed on the merits of their case.
On August 1, defendants filed a notice of appeal in the U.S. Court of Appeals for the First Circuit (25-1726). Over two months later, on October 7, defendants filed a brief seeking oral argument and claiming that the District Court had abused its discretion when it granted plaintiffs' preliminary injunction.
On October 14, Chief Judge David J. Barron stayed the case pending the end of the government shutdown. On October 15, District Judge Casper also stayed the case until October 31, due to the government shutdown. On October 31, the motion to stay expired in the District Court and Judge Casper set a schedule for the parties to file cross-motions for summary judgment.
On November 24, 2025, the First Circuit lifted the stay of proceedings because the government resumed its civil litigation functions.
On November 24, 2025, the defendant-appellants filed their brief, challenging the injunction on multiple grounds including that the district court abused its discretion by halting Sections 2(a), 2(d), 3(d), and 7(a) of the EO without proper legal justification. The government contended that Section 2(a), which directed the Election Assistance Commission (EAC) to require documentary proof of citizenship on the Federal Form, complied with the NVRA and did not preempt the EAC’s statutory discretion, that Section 2(d), requiring federal voter registration agencies to assess citizenship imposed no obligations on states and thus lacked standing for challenge, and that Section 3(d), which updated the Federal Post Card Application to include proof-of-citizenship requirements, was consistent with the UOCAVA. Finally, it argued that Section 7(a), directing enforcement of federal election day statutes, was not ripe for review and did not preempt state laws allowing post-election ballot counting.
On December 11, 2025, back in the district court, the defendants filed a stipulation regarding voluntary conditional dismissal of the plaintiffs' challenge to Section 2(d) of the Executive Order, which requires the heads of federal voter registration agencies to assess citizenship prior to providing a federal voter registration form to enrollees of public assistance programs. The plaintiffs agreed that they would dismiss their challenges so long as the requirement does not apply to voters in state or local elections. The defendants stipulated that they would not take action pursuant to the EO to require a plaintiff state to assess a person's citizenship prior to providing them with a federal voter registration form. District Judge Casper entered the stipulation on December 22, 2025.
On December 12, 2025, in the district court, the parties filed cross motions for summary judgment. The defendants moved for summary judgment to dismiss all claims brought by the plaintiffs.The defendants contended that the state plaintiffs lacked standing and that their claims were not ripe, as their alleged injuries were speculative and contingent on future agency actions not yet finalized, and that the claims were premature under the Administrative Procedure Act. They further asserted that the challenged provisions were lawful exercises of presidential authority under Article II and existing federal statutes, including the National Voter Registration Act and the Uniformed and Overseas Citizens Absentee Voting Act. The plaintiffs filed a motion for partial summary judgment arguing that Sections 2(a), 3(d)(i), 7(a), and 7(b) were ultra vires, unconstitutional, and preempted by federal statutes, including the National Voter Registration Act and the Uniformed and Overseas Citizens Absentee Voting Act. The plaintiffs requested declaratory relief and a permanent injunction barring enforcement of the challenged provisions, with tailored relief against the Election Assistance Commission, the Secretary of Defense, and the Attorney General. The plaintiff states contended that the EO unlawfully commandeered state resources and would cause irreparable harm, including resource diversion and reputational damage.
Back in the First Circuit, on January 5, 2026, the plaintiff-appellees filed their brief contending that the EO's proof-of-citizenship mandates conflicted with statutory text and precedent, including Arizona v. Inter Tribal Council of Arizona, Inc., 570 U.S. 1 (2013) and that Section 7(a) improperly preempted state ballot-receipt deadlines. They further argued that enforcement of the Order would cause irreparable harm, justifying the injunction's affirmation.
On January 26, 2026, the defendants-appellants filed a reply brief that reiterated its arguments that the district court erred in finding plaintiffs likely to succeed on the merits, as the challenges were not ripe, lacked standing, and failed to demonstrate irreparable harm. They further contended the injunction was overbroad, applying nationwide despite only 19 state plaintiffs
On February 24, 2026, the First Circuit calendared the case for oral argument to be heard on April 7. The appellants requested that the court reschedule the oral argument. On February 27, 2026, the court rescheduled oral argument for December 9, 2026.
On February 26, 2026, the district court heard the cross motions for summary judgment.
On March 27, 2026, the parties filed a joint stipulation regarding the pending summary judgment motions. The parties agreed to resolve claims regarding Sections 3(d)(ii) and 4(a) without further briefing, treating prior arguments as a motion for partial summary judgment, and stipulated to dismiss Section 2(d) contingent on the defendants' agreement not to enforce it.
On June 24, 2026, District Judge Casper entered and adopted the parties' stipulation and ruled on the cross motions for summary judgment. The court held that most of the plaintiffs had standing and that their claims were ripe; therefore, they could properly challenge the order's provisions requiring documentary proof of citizenship for voter registration, imposing funding conditions on noncompliant states, and enforcing Election Day ballot-receipt deadlines. The court granted the defendants’ motion for summary judgment against Wisconsin and non-Ballot Receipt States because they failed to establish standing. The court reasoned that Wisconsin did not suffer an injury in fact because it failed to provide undisputed evidence from the states’ chief election officials that the EO would “result in considerable implementation costs for the state.” Similarly, the court found that the non-Ballot Receipt states (Connecticut, Delaware, Maine, Minnesota, Vermont, and Wisconsin) failed to offer any evidence supporting imminent harm and could not sustain their claims. However, as to the remaining states, the court concluded that the challenged EO sections exceeded the President's constitutional authority, violated the separation of powers, and conflicted with federal statutes such as the NVRA, the UOCAVA, and the HAVA. The court therefore granted declaratory and permanent injunctive relief, voiding the provisions nationwide (except as to Wisconsin and non-Ballot Receipt States) and enjoined their enforcement. The parties were ordered to confer on remaining claims by July 10, 2026. 2026 WL 1826535.
On July 10, 2026, the parties jointly stipulated to dismiss the remaining claims without prejudice.
On July 13, 2026, District Judge Casper entered a judgment and order of permanent injunction. The Court permanently enjoined federal defendants, including the EAC and the Attorney General, from enforcing the invalidated provisions that required documentary proof of citizenship, alterations to federal post card forms, grant conditioning, and Election Day ballot receipt deadlines.
On September 9, 2026, the defendants appealed this judgment to the United States Court of Appeals for the First Circuit (Case No. 26-2038).
As of September 22, 2026, both appeals are pending.
Summary Authors
Haleigh Knowles (9/15/2026)
Alaa Mustafa (4/12/2025)
Jeremiah Price (6/16/2025)
Madeline Kaplan (11/19/2025)
People
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69841778/parties/state-of-california-v-trump/
Arguin, James J. (Massachusetts)
Adame, Michael (Massachusetts)
Aden, Leah C. (Massachusetts)
Ahmad, Alizeh (Massachusetts)
Alicea, Delmarie (Massachusetts)
Arguin, James J. (Massachusetts)
Baumann, Peter (Massachusetts)
Behrens, Angela (Massachusetts)
Bellows, Anne P. (Massachusetts)
Bolton, Jonathan Richard (Massachusetts)
Brown, Anthony G. (Massachusetts)
Brudigam, Malcolm Andreas (Massachusetts)
Campbell, Andrea J. (Massachusetts)
Clark, Charity R. (Massachusetts)
Cohen, Michael Surren (Massachusetts)
Day, David Dana (Massachusetts)
Donaghy, Maryanne (Massachusetts)
Echeverria, John D. (Massachusetts)
Ehrlich, Lisa Catherine (Massachusetts)
Ellison, Keith (Massachusetts)
Faherty, Colleen K. (Massachusetts)
Farrell, Peter (Massachusetts)
Fernandes, Kalikoonalani Diara (Massachusetts)
Fischer-Groban, Phoebe (Massachusetts)
Ford, Aaron D. (Massachusetts)
Frey, Aaron M. (Massachusetts)
Gibson, Charlotte (Massachusetts)
Grayson, James (Massachusetts)
Green, Nicholas Reiss (Massachusetts)
Harbourt, Samuel T. (Massachusetts)
Hartman-Tellez, Karen (Massachusetts)
Hunger, Sarah A. (Massachusetts)
James, Letitia (Massachusetts)
Jennings, Kathleen (Massachusetts)
Jr, Michael P. (Massachusetts)
Kane, Ryan Patrick (Massachusetts)
Karlson, Kara M (Massachusetts)
Kassab, Vanessa L. (Massachusetts)
Kaul, Joshua L. (Massachusetts)
Kirschner, Adam (Massachusetts)
Kobrin, Daniel Michael (Massachusetts)
Kramer, Elizabeth C. (Massachusetts)
Liston, Ian R. (Massachusetts)
Lopez, Anne E. (Massachusetts)
Mangel, Jonathan B. (Massachusetts)
Mayes, Kristin K. (Massachusetts)
Meingast, Heather S. (Massachusetts)
Moore, Michael Patrick (Massachusetts)
Murphy, Maura Bridget (Massachusetts)
Neronha, Peter F. (Massachusetts)
Newby, Craig A. (Massachusetts)
Pappavaselio, Chris (Massachusetts)
Patterson, Thomas (Massachusetts)
Platkin, Matthew J. (Massachusetts)
Quade, Kevin Lee (Massachusetts)
Sterman, Anne L. (Massachusetts)
Stern, Heidi Parry (Massachusetts)
Stevenson, Shannon Wells (Massachusetts)
Tong, William M. (Massachusetts)
Trento, Andrea (Massachusetts)
Underwood, Barbara D. (Massachusetts)
Vale, Judith N. (Massachusetts)
Adame, Michael (Massachusetts)
Alicea, Delmarie (Massachusetts)
Avers, Robert L. (Massachusetts)
Baldwin, Anna Marks (Massachusetts)
Basile, Thomas J. (Massachusetts)
Bernstein, Richard D. (Massachusetts)
Bernstein, Inga S. (Massachusetts)
Bishop, Tyler L. (Massachusetts)
Brannon, Sarah (Massachusetts)
Buchanan, Ellie (Massachusetts)
Chaudhuri, Pooja (Massachusetts)
Chiu, David S. (Massachusetts)
Cusick, John S. (Massachusetts)
Driscoll, Robert Neil (Massachusetts)
Eisen, Norman Larry (Massachusetts)
Elias, Marc E. (Massachusetts)
Galindo, Miranda (Massachusetts)
Gans, David H. (Massachusetts)
Garber, Andrew B. (Massachusetts)
Gold, Sofia Fernandez (Massachusetts)
Gorod, Brianne J. (Massachusetts)
Greenbaum, Jon M. (Massachusetts)
Hancock, William (Massachusetts)
Haskin, Brendan J. (Massachusetts)
Herenstein, Ethan (Massachusetts)
Jarboe, Brendan T. (Massachusetts)
Koch, Jonathan B. (Massachusetts)
Kovacs-Goodman, Jacob (Massachusetts)
Lakin, Sophia Lin (Massachusetts)
Lang, Danielle Marie (Massachusetts)
Langhofer, Kory (Massachusetts)
Lopresti, Tony (Massachusetts)
Madduri, Lalitha (Massachusetts)
Mays, Tianna Jade (Massachusetts)
McDaniel, Kalyn Mizelle (Massachusetts)
McSweeney, Patrick M. (Massachusetts)
Miller, Jonathan Benjamin (Massachusetts)
Morales-Doyle, Sean (Massachusetts)
Morgan, Jeremiah (Massachusetts)
Olson, William J. (Massachusetts)
Perlman, Samantha (Massachusetts)
Philbrick, Thomas J. (Massachusetts)
Pierce, Clayton (Massachusetts)
Ruiz, Cesar Z. (Massachusetts)
Shelly, Jacob D. (Massachusetts)
Sherman, Donald K. (Massachusetts)
Singh, Jasleen K. (Massachusetts)
Spies, Charles R. (Massachusetts)
Sweren-Becker, Eliza (Massachusetts)
Szilagyi, Heather (Massachusetts)
Temple, Nancy A. (Massachusetts)
Wright, Brenda (Massachusetts)
Documents in the Clearinghouse
Resources
Docket
See docket on RECAP: https://www.courtlistener.com/docket/69841778/state-of-california-v-trump/
Last updated Nov. 8, 2026, 4:16 a.m.
Docket for: State of California v. Trump
Case Details
State / Territory:
Case Type(s):
Special Collection(s):
Trump Administration 2.0: Challenges to the Government
Key Dates
Filing Date: April 3, 2025
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
Nineteen States
Plaintiff Type(s):
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Federal
Department of Justice
President
United States Election Assistance Commission
Defendant Type(s):
Facility Type(s):
Case Details
Causes of Action:
Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.
Ex Parte Young (Federal) or Bivens
Ex parte Young (federal or state officials)
Help America Vote Act (HAVA), 52 U.S.C. § 20901 et seq (previously 42 U.S.C. § 15301 et seq)
Constitutional Clause(s):
Spending/Appropriations Clauses
Other Dockets:
District of Massachusetts 1:25-cv-10810
U.S. Court of Appeals for the First Circuit 25-01726
U.S. Court of Appeals for the First Circuit 26-02038
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Plaintiff OR Mixed
Relief Granted:
Injunction / Injunctive-like Settlement
Preliminary injunction / Temp. restraining order
Source of Relief:
Form of Settlement:
Content of Injunction:
Issues
Voting:
Case Summary of State of California v. Trump, Civil Rights Litig. Clearinghouse, https://clearinghouse.net/case/46337/ (last updated 11/19/2025).