Case: State of California v. United States Department of Transportation

President Donald Trump

President Donald Trump

COMPLAINT ( filing fee paid $ 405.00, receipt number ARIDC-2134397 ), filed by Commonwealth of Massachusetts, State of Connecticut, State of Oregon, State of Illinois, State of California, State of Vermont, State of New York, State of Minnesota, State of Colorado, State of New Jersey, State of Hawai'i, People of the State of Michigan, State of Wisconsin, State of Nevada, State of New Mexico, State of Delaware, State of Rhode Island, State of Washington, State of Maine, State of Maryland. (Attachments: # 1 Exhibit Exhibit A, # 2 Exhibit Exhibit B, # 3 Exhibit Exhibit C, # 4 Exhibit Exhibit D, # 5 Exhibit Exhibit E, # 6 Exhibit Exhibit F, # 7 Exhibit Exhibit G, # 8 Exhibit Exhibit H, # 9 Civil Cover Sheet Civil Cover Sheet)(Reynolds, Patrick) (Entered: 05/13/2025)

1 Exhibit Exhibit A

View on PACER

2 Exhibit Exhibit B

View on PACER

3 Exhibit Exhibit C

View on PACER

4 Exhibit Exhibit D

View on PACER

5 Exhibit Exhibit E

View on PACER

6 Exhibit Exhibit F

View on PACER

7 Exhibit Exhibit G

View on PACER

8 Exhibit Exhibit H

View on PACER

9 Civil Cover Sheet Civil Cover Sheet

View on PACER

CASE OPENING NOTICE ISSUED (Simoncelli, Michael) (Entered: 05/13/2025)

NOTICE of Appearance by Patrick S Reynolds on behalf of State of Rhode Island (Reynolds, Patrick) (Entered: 05/13/2025)

Case Assigned/Reassigned

Case assigned to Chief Judge John J. McConnell, Jr. and Magistrate Judge Patricia A. Sullivan. (Simoncelli, Michael)

NOTICE of Appearance by Delbert Tran on behalf of State of California (Tran, Delbert) (Entered: 05/14/2025)

NOTICE of Appearance by Robert Henry Weaver on behalf of State of Illinois (Weaver, Robert) (Entered: 05/14/2025)

NOTICE of Appearance by Kalikoonalani Diara Fernandes on behalf of State of Hawai'i (Fernandes, Kalikoonalani) (Entered: 05/14/2025)

NOTICE of Appearance by David Dana Day on behalf of State of Hawai'i (Day, David) (Entered: 05/14/2025)

NOTICE of Appearance by Heidi Parry Stern on behalf of State of Nevada (Stern, Heidi) (Entered: 05/14/2025)

NOTICE of Appearance by Jonathan T. Rose on behalf of State of Vermont (Rose, Jonathan) (Entered: 05/14/2025)

NOTICE of Appearance by James C. Luh on behalf of State of Maryland (Luh, James) (Entered: 05/14/2025)

NOTICE of Appearance by Neil Giovanatti on behalf of People of the State of Michigan (Giovanatti, Neil) (Entered: 05/14/2025)

AMENDED DOCUMENT by State of Vermont. Amendment to 5 Notice of Appearance CORRECTED. (Rose, Jonathan) (Entered: 05/14/2025)

NOTICE of Appearance by Alex Hemmer on behalf of State of Illinois (Hemmer, Alex) (Entered: 05/14/2025)

TEXT ORDER: Pursuant to LR Gen 101(c), the Court suspends LR Gen 201(a) and any attorney employed by a State or the District of Columbia and is a member in good standing of the bar of another federal district court and each jurisdiction in which that attorney has been admitted may appear and practice in this matter without being admitted pro hac vice. Attorneys appearing on behalf of the States and the District of Columbia are directed to obtain filing privileges via PACER and to enter their appearances. So Ordered by Chief Judge John J. McConnell, Jr. on 5/14/2025. (Simoncelli, Michael)

Order

TEXT ORDER: The parties are ordered to show cause by the close of business Monday, May 19, 2025, why this matter should not be consolidated with State of Illinois et al v. Federal Emergency Management Agency et al, C.A. No. 25-cv-206-WES-PAS under Fed. R. Civ. P. 42(a)(2) as the cases appear to involve common questions of law or fact. So Ordered by Chief Judge John J. McConnell, Jr. on 5/14/2025. (Jackson, Ryan)

NOTICE of Appearance by Katherine Brady Dirks on behalf of Commonwealth of Massachusetts (Dirks, Katherine) (Entered: 05/15/2025)

NOTICE of Appearance by Mayur Prasad Saxena on behalf of State of New Jersey (Saxena, Mayur) (Entered: 05/15/2025)

NOTICE of Appearance by Steven Perfrement on behalf of State of New Mexico (Perfrement, Steven) (Entered: 05/15/2025)

NOTICE of Appearance by Frances None Reynolds Colbert on behalf of State of Wisconsin (Reynolds Colbert, Frances) (Entered: 05/15/2025)

NOTICE of Appearance by Michael Kenneth Skold on behalf of State of Connecticut (Skold, Michael) (Entered: 05/16/2025)

NOTICE of Appearance by Michael James Dittenber on behalf of People of the State of Michigan (Dittenber, Michael) (Entered: 05/19/2025)

Summons Request filed by State of Rhode Island. (Attachments: # 1 Summons Request - Duffy)(Reynolds, Patrick) (Entered: 05/19/2025)

NOTICE of Appearance by Michael Mark Tresnowski on behalf of State of Illinois (Tresnowski, Michael) (Entered: 05/19/2025)

Summons Issued as to Sean P. Duffy, United States Department of Transportation (Attachments: # 1 Summons)(Hill, Cherelle) (Entered: 05/19/2025)

NOTICE of Appearance by Lee Sherman on behalf of State of California (Sherman, Lee) (Entered: 05/19/2025)

NOTICE of Appearance by Newton Knowles, III on behalf of State of California (Knowles, Newton) (Entered: 05/19/2025)

RESPONSE TO ORDER TO SHOW CAUSE by State of California. (Tran, Delbert) (Entered: 05/19/2025)

NOTICE of Appearance by Samuel Perry Wolter on behalf of State of Colorado (Wolter, Samuel) (Entered: 05/19/2025)

NOTICE of Appearance by Cristina Sepe on behalf of State of Washington (Sepe, Cristina) (Entered: 05/19/2025)

NOTICE of Appearance by Benjamin M. Seel on behalf of State of Washington (Seel, Benjamin) (Entered: 05/19/2025)

NOTICE of Appearance by Marsha Chien on behalf of State of Washington (Chien, Marsha) (Entered: 05/19/2025)

NOTICE of Appearance by Tyler S. Roberts on behalf of State of Washington (Roberts, Tyler) (Entered: 05/19/2025)

NOTICE of Appearance by Christopher Paul Kailani Medeiros on behalf of State of California (Medeiros, Christopher) (Entered: 05/19/2025)

NOTICE of Appearance by Deylin O Thrift-Viveros on behalf of State of California (Thrift-Viveros, Deylin) (Entered: 05/19/2025)

NOTICE of Appearance by Luke Freedman on behalf of State of California (Freedman, Luke) (Entered: 05/19/2025)

NOTICE of Appearance by Julie Dona on behalf of State of New York (Dona, Julie) (Entered: 05/20/2025)

NOTICE of Appearance by Julio A Thompson on behalf of State of Vermont (Thompson, Julio) (Entered: 05/20/2025)

NOTICE of Appearance by Mark H. Ladov on behalf of State of New York (Ladov, Mark) (Entered: 05/20/2025)

NOTICE of Appearance by James Edward Stanley on behalf of State of California (Stanley, James) (Entered: 05/20/2025)

Order

TEXT ORDER: The Court has determined at this time that this case should not be consolidated with State of Illinois et al v. Federal Emergency Management Agency et al, C.A. No. 25-cv-206-WES-PAS. So Ordered by Chief Judge John J. McConnell, Jr. on 5/20/2025. (Jackson, Ryan)

NOTICE of Appearance by Rabia Muqaddam on behalf of State of New York (Muqaddam, Rabia) (Entered: 05/21/2025)

NOTICE of Appearance by Shankar Duraiswamy on behalf of State of New Jersey (Duraiswamy, Shankar) (Entered: 05/21/2025)

NOTICE of Appearance by Zoe Levine on behalf of State of New York (Levine, Zoe) (Entered: 05/21/2025)

MOTION for Preliminary Injunction filed by All Plaintiffs. Responses due by 6/5/2025. (Attachments: # 1 PLAINTIFF STATES REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF PLAINTIFF STATES' MOTION FOR A PRELIMINARY INJUNCTION)(Tran, Delbert) (Entered: 05/22/2025)

1 PLAINTIFF STATES REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF PLAINTIFF STATES

View on RECAP

EXHIBIT IN SUPPORT by All Plaintiffs in support of 41 MOTION for Preliminary Injunction . (Attachments: # 1 INDEX OF EXHIBITS TO PLAINTIFF STATES MOTION FOR A PRELIMINARY INJUNCTION VOLUME II OF II)(Tran, Delbert) (Entered: 05/22/2025)

1 INDEX OF EXHIBITS TO PLAINTIFF STATES MOTION FOR A PRELIMINARY INJUNCTION VOLUM

View on RECAP

AMENDED DOCUMENT by State of California. Amendment to 42 Exhibit in Support, 41 MOTION for Preliminary Injunction AMENDED DECLARATION OF SERVICE BY E-MAIL 1. (Tran, Delbert) (Entered: 05/22/2025)

NOTICE of Appearance by Thomas H. Castelli on behalf of State of Oregon (Castelli, Thomas) (Entered: 05/22/2025)

Order

TEXT ORDER re: 41 MOTION for Preliminary Injunction: The parties will meet and confer to submit a joint scheduling plan for fully briefing the newly-filed preliminary injunction motion dates for objections and a reply. So Ordered by Chief Judge John J. McConnell, Jr. on 5/22/2025. (Jackson, Ryan)

NOTICE of Appearance by Brian S. Carter on behalf of State of Minnesota (Carter, Brian) (Entered: 05/23/2025)

NOTICE of Appearance by Sara Miron Bloom on behalf of All Defendants (Bloom, Sara) (Entered: 05/23/2025)

NOTICE of Appearance by Joel Marrero on behalf of State of California (Marrero, Joel) (Entered: 05/23/2025)

NOTICE of Appearance by Rachna Vyas on behalf of All Defendants (Vyas, Rachna) (Entered: 05/23/2025)

First MOTION to Amend/Correct 41 MOTION for Preliminary Injunction filed by State of California. Responses due by 6/6/2025. (Attachments: # 1 Supplement Declaration of Deylin Thrift-Viveros in support of Plaintiff State's Amended Motion for a Preliminary Injunction, # 2 Supplement Declaration of Service by E-mail)(Thrift-Viveros, Deylin) (Entered: 05/23/2025)

TEXT ORDER: Defendants' response to the Motion for a Preliminary Injunction 41 is due June 5, 2025; Plaintiffs' reply is due June 9, 2025. So Ordered by Chief Judge John J. McConnell, Jr. on 5/27/2025. (Jackson, Ryan)

Order on Motion to Amend/Correct

Order

TEXT ORDER granting 49 Motion to Amend 41 Motion for Preliminary Injunction. So Ordered by Chief Judge John J. McConnell, Jr. on 5/27/2025. (Jackson, Ryan)

SUMMONS Returned Executed by State of Rhode Island. Sean P. Duffy served on 5/28/2025, answer due 6/18/2025; United States Department of Transportation served on 5/28/2025, answer due 6/18/2025. (Attachments: # 1 Summons Executed - Duffy)(Reynolds, Patrick) (Entered: 05/29/2025)

RESPONSE In Opposition to 49 First MOTION to Amend/Correct 41 MOTION for Preliminary Injunction, 41 MOTION for Preliminary Injunction filed by Sean P. Duffy, United States Department of Transportation. Replies due by 6/12/2025. (Attachments: # 1 Affidavit Declaration of Rhea Hubbard)(Vyas, Rachna) (Entered: 06/05/2025)

1 Affidavit Declaration of Rhea Hubbard

View on PACER

MOTION for Leave to File Amicus Brief filed by Immigration Reform Law Institute. Responses due by 6/23/2025. (Attachments: # 1 Supporting Memorandum Proposed Amicus)(Larisa, Joseph) (Entered: 06/09/2025)

REPLY to Response re 51 Response to Motion, filed by All Plaintiffs. (Tran, Delbert) (Entered: 06/09/2025)

TEXT ORDER denying 52 Motion for Leave to File Amicus Brief: The Court is not accepting Amici briefs in this case; both sides are adequately represented in this legal matter. So Ordered by Chief Judge John J. McConnell, Jr. on 6/10/2025. (Jackson, Ryan)

Order on Motion for Leave to File Amicus Brief

NOTICE of Appearance by Hannah Vail on behalf of Commonwealth of Massachusetts (Vail, Hannah) (Entered: 06/11/2025)

NOTICE of Hearing on 41 MOTION for Preliminary Injunction: Motion Hearing scheduled for Tuesday 6/17/2025 at 9:30 AM in Courtroom 1 before Chief Judge John J. McConnell, Jr. This hearing will be available for viewing via the Court's YouTube channel (details will be available on the Court's website the day of the hearing). (Jackson, Ryan)

NOTICE of Hearing on 41 MOTION for Preliminary Injunction: Motion Hearing scheduled for Tuesday 6/17/2025 at 9:30 AM in Courtroom 1 before Chief Judge John J. McConnell, Jr. This hearing will be available for viewing via the Court's YouTube channel (details will be available on the Court's website the day of the hearing). (Jackson, Ryan)

Reset Hearings re: Notice of Hearing on 41 MOTION for Preliminary Injunction: Motion Hearing RESCHEDULED to MONDAY 6/30/2025 at 10:00 AM in Courtroom 1 before Chief Judge John J. McConnell, Jr.; In light of a Court Scheduling Conflict, this matter is hereby RESCHEDULED. This hearing will be available for viewing via the Court's YouTube channel (details will be available on the Court's website the day of the hearing) (Jackson, Ryan)

Reset Hearings re: Notice of Hearing on 41 MOTION for Preliminary Injunction: Motion Hearing RESCHEDULED to MONDAY 6/30/2025 at 10:00 AM in Courtroom 1 before Chief Judge John J. McConnell, Jr.; In light of a Court Scheduling Conflict, this matter is hereby RESCHEDULED. This hearing will be available for viewing via the Court's YouTube channel (details will be available on the Court's website the day of the hearing) (Jackson, Ryan)

Reset Hearings re: Notice of Hearing on 41 MOTION for Preliminary Injunction: Motion Hearing RESCHEDULED to WEDNESDAY 6/18/2025 at 9:00 AM in Courtroom 1 before Chief Judge John J. McConnell, Jr. This matter is hereby RESCHEDULED at the request of counsel for both parties. The hearing previously scheduled for 6/30/25 is hereby CANCELLED.This hearing will be available for viewing via the Court's YouTube channel (details will be available on the Court's website the day of the hearing). Each party will be limited to 45 minutes for their respective arguments at this hearing. (Jackson, Ryan)

NOTICE of Appearance by Robert Newman Brewer on behalf of State of Maryland (Brewer, Robert) (Entered: 06/17/2025)

Minute Entry for proceedings held before Chief Judge John J. McConnell, Jr.: Motion Hearing held on 6/18/2025 re: 41 MOTION for Preliminary Injunction filed by State of Rhode Island, et al.: Counsel present: D. Tran, P. Reynolds; S. Bloom, K. Hubbard. Plaintiffs (Tran) argue their motion for preliminary injunction; Court questions plaintiffs. Defendants (Bloom) argue against the motion; Court questions defendants. Plaintiffs give brief rebuttal argument. Court takes the matter under advisement. Adjourned. (Court Reporter Denise Veitch in Courtroom 1 at 9:05 AM) (Jackson, Ryan)

NOTICE of Appearance by Brandy Doyle on behalf of State of California (Doyle, Brandy) (Entered: 06/19/2025)

PRELIMINARY INJUNCTION entered and Defendants' request to stay is denied. So Ordered by Chief Judge John J. McConnell, Jr. on 6/19/2025. (Perry, Frank) (Entered: 06/19/2025)

TRANSCRIPT ORDER for proceedings held on 06/18/2025 before Judge Chief Judge McConnell. 3-Day Transcript Selected. Transcript to be delivered within 3 calendar days.. (Tran, Delbert) (Entered: 06/25/2025)

TRANSCRIPT ORDER ACKNOWLEDGMENT Entered re: 58 Transcript Order. Court Reporter/Transcriber: Denise Veitch. (Dias, Jennifer) (Entered: 06/27/2025)

TRANSCRIPT of Plaintiff States' Motion for Preliminary Injunction, held on June 18, 2025, before Chief Judge John J. McConnell, Jr. Court Reporter Denise P. Veitch, Telephone number (401) 752-7031. Transcript may be viewed at the court public terminal or purchased through the Court Reporter before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter or PACER. NOTICE TO COUNSEL: Redaction Requests must be filed for personal identifiers only. All other redactions must be requested by motion. For local policy and sample redaction request visit our website at www.rid.uscourts.gov and select Transcripts under the Case Information menu option. Redaction Request due 7/22/2025. Redacted Transcript Deadline set for 8/1/2025. Release of Transcript Restriction set for 9/29/2025. (Veitch, Denise) (Entered: 07/01/2025)

AMENDED COMPLAINT FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF against Sean P. Duffy, United States Department of Transportation, filed by Commonwealth of Massachusetts, State of Connecticut, State of Oregon, State of Illinois, State of California, State of Vermont, State of New York, State of Minnesota, State of Colorado, State of New Jersey, State of Hawai'i, People of the State of Michigan, State of Wisconsin, State of Nevada, State of New Mexico, State of Delaware, State of Rhode Island, State of Washington, State of Maine, State of Maryland.(Tran, Delbert) Modified on 7/9/2025: removed a non-filing party that was inadvertently connected as a "filer" of this event. (Jackson, Ryan). (Entered: 07/08/2025)

First MOTION to Amend/Correct 57 Preliminary Injunction Plaintiffs States' Motion to Modify Preliminary Injunction filed by State of California. Responses due by 7/24/2025. (Attachments: # 1 Exhibit First Amended Complaint for Declaratory and Injunctive Relief, # 2 Exhibit Declaration of Sharon Kershbaum, # 3 Exhibit Declaration of James P. Gray)(Tran, Delbert) (Entered: 07/10/2025)

1 Exhibit First Amended Complaint for Declaratory and Injunctive Relief

View on RECAP

2 Exhibit Declaration of Sharon Kershbaum

View on RECAP

3 Exhibit Declaration of James P. Gray

View on RECAP

TRANSCRIPT ORDER for proceedings held on 06/18/2025 before Judge Judge Chief Judge McConnell. Daily Transcript selected. Transcript to be delivered following adjournment and prior to the normal opening hour of court on the following morning.. (Sellstrom, Oren) (Entered: 07/11/2025)

TRANSCRIPT ORDER for proceedings held on 06/18/2025 before Judge Judge Chief Judge McConnell. Daily Transcript selected. Transcript to be delivered following adjournment and prior to the normal opening hour of court on the following morning.. (Sellstrom, Oren) (Entered: 07/11/2025)

TRANSCRIPT ORDER ACKNOWLEDGMENT Entered re: 63 Transcript Order. Daily Transcript Ordered. Court Reporter/Transcriber: Denise Veitch. (Simoncelli, Michael) (Entered: 07/11/2025)

TRANSCRIPT ORDER ACKNOWLEDGMENT Entered re: 63 Transcript Order. Daily Transcript Ordered. Court Reporter/Transcriber: Denise Veitch. (Simoncelli, Michael) (Entered: 07/11/2025)

RESPONSE In Opposition to 62 First MOTION to Amend/Correct 57 Preliminary Injunction Plaintiffs States' Motion to Modify Preliminary Injunction filed by Sean P. Duffy, United States Department of Transportation. Replies due by 7/23/2025. (Vyas, Rachna) (Entered: 07/16/2025)

Order on Motion to Amend/Correct

TEXT ORDER granting 62 Motion to Amend the Preliminary Injunction: Plaintiff's Motion to Amend the Preliminary Injunction 62 is GRANTED. The Plaintiff has shown through their submission that the preliminary injunction should apply to newly added Plaintiffs the District of Columbia and the Commonwealth of Kentucky for all the reasons the Court has previously ruled the preliminary injunction should apply to the original state Plaintiffs. The Defendants produced no counter evidence. So Ordered by Chief Judge John J. McConnell, Jr. on 7/17/2025. (Jackson, Ryan)

NOTICE of Appearance by Mitchell Reich on behalf of District of Columbia (Reich, Mitchell) (Entered: 07/22/2025)

Joint MOTION to Expedite Briefing Schedule filed by Sean P. Duffy, United States Department of Transportation. Responses due by 8/7/2025. (Vyas, Rachna) (Entered: 07/24/2025)

Order on Motion to Expedite

TEXT ORDER granting 67 Motion to Expedite Briefing Schedule: Plaintiffs will file their motion for summary judgment and Defendants will file their cross-motion for summary judgment on or before 8/19/25. Defendants will file their opposition and reply to Plaintiffs' motion for summary judgment and Plaintiffs will file their opposition and reply to Defendants' cross-motion for summary judgment on or before 9/24/25. So Ordered by Chief Judge John J. McConnell, Jr. on 7/25/2025. (Jackson, Ryan)

Cross MOTION for Summary Judgment filed by Sean P. Duffy, United States Department of Transportation. Responses due by 9/2/2025. (Attachments: # 1 Affidavit Declaration of Loren A. Smith, # 2 Affidavit Declaration of Shannon Louie)(Vyas, Rachna) (Entered: 08/19/2025)

1 Affidavit Declaration of Loren A. Smith

View on PACER

2 Affidavit Declaration of Shannon Louie

View on PACER

MOTION for Summary Judgment PLAINTIFF STATES MOTION FOR SUMMARY JUDGMENT filed by All Plaintiffs. Responses due by 9/2/2025. (Attachments: # 1 PLAINTIFF STATES REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF PLAINTIFF STATES MOTION FOR SUMMARY JUDGMENT, # 2 Exhibit INDEX OF EXHIBITS TO PLAINTIFF STATES MOTION FOR SUMMARY JUDGMENT VOLUME I OF IV, # 3 Exhibit INDEX OF EXHIBITS TO PLAINTIFF STATES MOTION FOR SUMMARY JUDGMENT VOLUME II OF IV, # 4 Exhibit INDEX OF EXHIBITS TO PLAINTIFF STATES MOTION FOR SUMMARY JUDGMENT VOLUME III OF IV, # 5 Exhibit INDEX OF EXHIBITS TO PLAINTIFF STATES MOTION FOR SUMMARY JUDGMENT VOLUME IV OF IV)(Tran, Delbert) (Entered: 08/19/2025)