Case: State of California v. U.S. Department of Health and Human Services

3:25-cv-05536 | U.S. District Court for the Northern District of California

Filed Date: July 1, 2025

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Case Summary

This case challenged the Trump administration’s disclosure of confidential Medicaid beneficiary data to the Department of Homeland Security (DHS) for immigration enforcement. On July 1, 2025, twenty-one states and the District of Columbia filed this lawsuit in the U.S. District Court for the Northern District of California against the U.S. Department of Health and Human Services (HHS), Secretary Robert F. Kennedy Jr., the U.S. Department of Homeland Security (DHS), and Secretary Kristi Noem. The plaintiffs, represented by their respective state attorneys general, sought declaratory and injunctive relief, alleging violations of the Administrative Procedure Act (APA), the Privacy Act, the Health Insurance Portability and Accountability Act (HIPAA), the Federal Information Security Management Act (FISMA), and constitutional claims under the Spending Clause and separation-of-powers principles.

The case was assigned to Judge Vince Chhabria.

Plaintiffs alleged that in early June 2025, HHS’s Centers for Medicare and Medicaid Services (CMS) secretly transferred Medicaid beneficiary data—including names, addresses, Medicaid IDs, immigration status, and potentially protected health information—to DHS. Following internal agency objections, HHS and Immigration and Customs Enforcement (ICE) formalized this arrangement on July 9, 2025, through an Interagency Exchange Agreement (IEA), granting ICE direct access to CMS’s Integrated Data Repository and the Transformed Medicaid Statistical Information System (T-MSIS), containing over 78 million Medicaid beneficiaries’ personal records. Plaintiffs claimed this unprecedented transfer violated federal statutes strictly limiting disclosure of Medicaid data to purposes directly connected to Medicaid administration, and undermined decades of federal assurances regarding patient privacy.

Plaintiffs also alleged procedural and constitutional violations. They asserted that HHS’s decision constituted a final agency action requiring notice-and-comment rulemaking under the APA, that it was arbitrary and capricious for failing to consider reliance interests and severe public health consequences, and that the new data-sharing policy retroactively imposed ambiguous, coercive conditions on federal Medicaid funding contrary to the Spending Clause.

On July 11, plaintiffs filed a motion for a preliminary injunction, seeking to prohibit HHS from further transferring Medicaid data to DHS, the Department of Government Efficiency (DOGE), or other federal agencies, and to bar DHS from using the data for immigration enforcement or population surveillance. In support, plaintiffs submitted declarations from senior Medicaid officials in California, Washington, Maryland, Delaware, and representatives of healthcare providers. These declarations detailed irreparable harms already suffered, including widespread fear and disenrollment from Medicaid programs among immigrant communities; reduced use of necessary emergency and preventive healthcare services; and substantial financial burdens on healthcare providers and states due to uncompensated care and lost federal funding.

On July 14, the parties stipulated to expedite briefing on the preliminary injunction, and the court scheduled oral argument for August 7, 2025. On August 12, 2025, the court granted in part and denied in part the motion for a preliminary injunction. 2025 WL 2356224. At the outset, it noted that there did not appear to be anything categorically unlawful about DHS obtaining data from agencies like HHS for immigration enforcement purposes, and that several federal statutes appeared to permit, and sometimes even require, such disclosures. Nonetheless, in light of existing, longstanding ICE policy against using Medicaid data for immigration enforcement, and reliance on that policy by states, providers, and patients, "it was incumbent upon the agencies to carry out a reasoned decisionmaking process before changing them." The record in this case suggested that no such process occurred, and that the defendants did not consider important policy tradeoffs before making the challenged changes. Thus, the court concluded that, on the record before it, the states had demonstrated a likelihood of success on their “arbitrary and capricious” claim under the APA, which would require HHS and DHS to go back and engage in a reasoned decisionmaking process. Moreover, the states were likely to suffer irreparable harm from the way the agencies implemented the change, and the balance of hardships and public interest further warranted preliminary relief. The court therefore preliminarily enjoined DHS from using Medicaid data obtained from the plaintiff states for immigration enforcement purposes, including data already acquired from CMS, and preliminarily enjoined HHS from sharing Medicaid data obtained from the plaintiff states with DHS for immigration enforcement purposes. The preliminary injunction was to remain in place until the shorter of: (1) the termination of this litigation; or (2) 14 days after both DHS and HHS have completed a reasoned decisionmaking process or rulemaking, if necessary. The court declined, however, to require the agencies to undertake notice and comment rulemaking, holding that the states had not demonstrated that such rulemaking was required. It noted that this was without prejudice to re-raising the issue later. It further noted its skepticism on the merits of the plaintiffs' Spending Clause claim, but denied it as moot in light of the ruling under the APA which would enable the agencies to consider the Spending Clause issue as part of the reasoned decisionmaking process.

	Document
1 3:25-cv-05536	Complaint for Declaratory and Injunctive Relief	July 1, 2025	July 1, 2025 Complaint
43 3:25-cv-05536	Plaintiffs' Notice of Motion and Motion for Preliminary Injunction	July 11, 2025	July 11, 2025 Pleading / Motion / Brief
98 3:25-cv-05536	Order Granting in Part and Denying in Part Motion for Preliminary Injunction	Aug. 12, 2025	Aug. 12, 2025 Order/Opinion 2025 WL 2356224

Title	Description		External URL Date / External URL
EO 14243 - Stopping Waste, Fraud, and Abuse by Eliminating Information Silos President Donald Trump	Directing all agency heads to ensure that federal officials have "full and prompt access to all unclassified agency records, data, software systems, and information technology systems...for the purpo…	March 20, 2025	March 20, 2025 https://www.federalregister.gov/...
EO 14218 - Ending Taxpayer Subsidization of Open Borders President Donald Trump	Directing each executive department or agency to (1) identify all federally funded programs administered by the agency that permit undocumented immigrants to obtain any cash or non-cash public benefi…	Feb. 19, 2025	Feb. 19, 2025 https://www.federalregister.gov/...

ECF Number	Description	Date	Link Date / Link
1	COMPLAINT against Robert F. Kennedy, Jr, Kristi Noem, U.S. Department of Health and Human Services, U.S. Department of Homeland Security ( Filing fee $ 405, receipt number ACANDC-20849352.). Injunction against the US government/official or APA vacatur requested. Filed by State of Michigan, State of Illinois, State of Arizona, State of Oregon, State of California, State of Rhode Island, State of Nevada, State of New York, State of Hawaii, State of Colorado, State of Maryland, State of Minnesota, State of New Jersey, State of New Mexico, State of Washington, State of Maine, State of Connecticut, State of Massachusetts, State of Vermont, State of Delaware. (Rich, Anna) (Filed on 7/1/2025) (Entered: 07/01/2025)	July 1, 2025	July 1, 2025 Clearinghouse
2	Proposed Summons. (Rich, Anna) (Filed on 7/1/2025) (Entered: 07/01/2025)	July 1, 2025	July 1, 2025 PACER
10	MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 328, receipt number ACANDC-20852879.) filed by State of Connecticut. (Attachments: # 1 Exhibit Certificate of Good Standing)(Medeiros, Janelle) (Filed on 7/2/2025) (Entered: 07/02/2025)	July 2, 2025	July 2, 2025 PACER
11	NOTICE of Appearance filed by Kathleen Boergers on behalf of State of California (Boergers, Kathleen) (Filed on 7/2/2025) (Entered: 07/02/2025)	July 2, 2025	July 2, 2025 PACER
12	Order by Judge Vince Chhabria granting 10 Motion for Pro Hac Vice as to Janelle Medeiros. (bxs, COURT STAFF) (Filed on 7/2/2025)Any non-CM/ECF Participants have been served by First Class Mail to the addresses of record listed on the Notice of Electronic Filing (NEF) (Entered: 07/02/2025)	July 2, 2025	July 2, 2025 PACER
13	Initial Case Management Scheduling Order with ADR Deadlines: Notice: The assigned judge participates in the Cameras in the Courtroom Pilot Project. See General Order 65 and cand.uscourts.gov/cameras. Case Management Statement due by 9/26/2025. Initial Case Management Conference set for 10/3/2025 10:00 AM in San Francisco, - Videoconference Only. (Attachments: # 1 Notice of Eligibility for Video Recording)(far, COURT STAFF) (Filed on 7/2/2025)Any non-CM/ECF Participants have been served by First Class Mail to the addresses of record listed on the Notice of Electronic Filing (NEF) (Entered: 07/02/2025)	July 2, 2025	July 2, 2025 PACER
14	Summons Issued as to Robert F. Kennedy, Jr, Kristi Noem, U.S. Department of Health and Human Services, U.S. Department of Homeland Security, U.S. Attorney and U.S. Attorney General (far, COURT STAFF) (Filed on 7/2/2025) (Entered: 07/02/2025)	July 2, 2025	July 2, 2025 PACER
15	MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 328, receipt number ACANDC-20854822.) filed by State of Washington. (Attachments: # 1 Certificate of Good Standing)(Muller, Zane) (Filed on 7/2/2025) (Entered: 07/02/2025)	July 2, 2025	July 2, 2025 PACER
3	Case assigned to Judge Vince Chhabria. Counsel for plaintiff or the removing party is responsible for serving the Complaint or Notice of Removal, Summons and the assigned judge's standing orders and all other new case documents upon the opposing parties. For information, visit E-Filing A New Civil Case at http://cand.uscourts.gov/ecf/caseopening.Standing orders can be downloaded from the court's web page at www.cand.uscourts.gov/judges. Upon receipt, the summons will be issued and returned electronically. A scheduling order will be sent by Notice of Electronic Filing (NEF) within two business days. (mbc, COURT STAFF) (Filed on 7/2/2025) (Entered: 07/02/2025)	July 2, 2025	July 2, 2025 PACER
4	MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 328, receipt number ACANDC-20852058.) filed by State of Washington. (Attachments: # 1 Certificate of Good Standing)(McGinty, William) (Filed on 7/2/2025) (Entered: 07/02/2025)	July 2, 2025	July 2, 2025 PACER
5	MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 328, receipt number ACANDC-20852548.) filed by State of Colorado. (Attachments: # 1 Exhibit Certificate of Good Standing)(Lorch, Ryan) (Filed on 7/2/2025) (Entered: 07/02/2025)	July 2, 2025	July 2, 2025 PACER
6	MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 328, receipt number ACANDC-20852588.) filed by State of Colorado. (Attachments: # 1 Exhibit Certificate of Good Standing)(Wolter, Samuel) (Filed on 7/2/2025) (Entered: 07/02/2025) 1 Exhibit Certificate of Good Standing View on PACER	July 2, 2025	July 2, 2025 PACER
7	Order by Judge Vince Chhabria granting 4 Motion for Pro Hac Vice as to William McGinty. (bxs, COURT STAFF) (Filed on 7/2/2025)Any non-CM/ECF Participants have been served by First Class Mail to the addresses of record listed on the Notice of Electronic Filing (NEF) (Entered: 07/02/2025)	July 2, 2025	July 2, 2025 PACER
8	Order by Judge Vince Chhabria granting 5 Motion for Pro Hac Vice as to Ryan Lorch. (bxs, COURT STAFF) (Filed on 7/2/2025)Any non-CM/ECF Participants have been served by First Class Mail to the addresses of record listed on the Notice of Electronic Filing (NEF) (Entered: 07/02/2025)	July 2, 2025	July 2, 2025 PACER
9	Order by Judge Vince Chhabria granting 6 Motion for Pro Hac Vice as to Samuel Wolter. (bxs, COURT STAFF) (Filed on 7/2/2025)Any non-CM/ECF Participants have been served by First Class Mail to the addresses of record listed on the Notice of Electronic Filing (NEF) (Entered: 07/02/2025)	July 2, 2025	July 2, 2025 PACER
	~Util - Case Assigned by Intake	July 2, 2025	July 2, 2025 PACER
	Notice of Appearance/Substitution/Change/Withdrawal of Attorney	July 2, 2025	July 2, 2025 PACER
16	MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 328, receipt number ACANDC-20856334.) filed by State of Michigan. (Giovanatti, Neil) (Filed on 7/3/2025) (Entered: 07/03/2025)	July 3, 2025	July 3, 2025 PACER
17	MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 328, receipt number ACANDC-20856548.) filed by State of Michigan. (Beach, Bryan) (Filed on 7/3/2025) (Entered: 07/03/2025)	July 3, 2025	July 3, 2025 PACER
18	MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 328, receipt number ACANDC-20856611.) filed by State of Rhode Island. (Attachments: # 1 Supplement Certificate of Good Standing)(Staley, Lee) (Filed on 7/3/2025) (Entered: 07/03/2025)	July 3, 2025	July 3, 2025 PACER
19	MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 328, receipt number ACANDC-20858411.) filed by State of Illinois. (Attachments: # 1 Exhibit Letter of Good Standing)(Gaber, Sherief) (Filed on 7/3/2025) (Entered: 07/03/2025)	July 3, 2025	July 3, 2025 PACER
20	Order by Judge Vince Chhabria granting 15 Motion for Pro Hac Vice as to Zane Muller. (bxs, COURT STAFF) (Filed on 7/3/2025)Any non-CM/ECF Participants have been served by First Class Mail to the addresses of record listed on the Notice of Electronic Filing (NEF) (Entered: 07/03/2025)	July 3, 2025	July 3, 2025 PACER
21	Order by Judge Vince Chhabria granting 16 Motion for Pro Hac Vice as to Neil Giovanatti. (bxs, COURT STAFF) (Filed on 7/3/2025)Any non-CM/ECF Participants have been served by First Class Mail to the addresses of record listed on the Notice of Electronic Filing (NEF) (Entered: 07/03/2025)	July 3, 2025	July 3, 2025 PACER
22	Order by Judge Vince Chhabria granting 17 Motion for Pro Hac Vice as to Bryan Beach. (bxs, COURT STAFF) (Filed on 7/3/2025)Any non-CM/ECF Participants have been served by First Class Mail to the addresses of record listed on the Notice of Electronic Filing (NEF) (Entered: 07/03/2025)	July 3, 2025	July 3, 2025 PACER
23	Order by Judge Vince Chhabria granting 18 Motion for Pro Hac Vice as to Lee Staley. (bxs, COURT STAFF) (Filed on 7/3/2025)Any non-CM/ECF Participants have been served by First Class Mail to the addresses of record listed on the Notice of Electronic Filing (NEF) (Entered: 07/03/2025)	July 3, 2025	July 3, 2025 PACER
24	Order by Judge Vince Chhabria granting 19 Motion for Pro Hac Vice as to Sherief Gaber. (bxs, COURT STAFF) (Filed on 7/3/2025)Any non-CM/ECF Participants have been served by First Class Mail to the addresses of record listed on the Notice of Electronic Filing (NEF) (Entered: 07/03/2025)	July 3, 2025	July 3, 2025 PACER
25	MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 328, receipt number ACANDC-20860734.) filed by State of Vermont. (Kane, Ryan) (Filed on 7/7/2025) (Entered: 07/07/2025)	July 7, 2025	July 7, 2025 PACER
26	Order by Judge Vince Chhabria granting 25 Motion for Pro Hac Vice as to Ryan Kane. (bxs, COURT STAFF) (Filed on 7/7/2025)Any non-CM/ECF Participants have been served by First Class Mail to the addresses of record listed on the Notice of Electronic Filing (NEF) (Entered: 07/07/2025)	July 7, 2025	July 7, 2025 PACER
27	NOTICE of Appearance filed by Ryan P. Kane on behalf of State of Vermont (Kane, Ryan) (Filed on 7/7/2025) (Entered: 07/07/2025)	July 7, 2025	July 7, 2025 PACER
28	MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 328, receipt number ACANDC-20862012.) filed by State of New York. (Attachments: # 1 Certificate of Good Standing)(Ladov, Mark) (Filed on 7/7/2025) (Entered: 07/07/2025)	July 7, 2025	July 7, 2025 PACER
29	MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 328, receipt number ACANDC-20863144.) filed by State of Hawaii. (Attachments: # 1 HI Certificate of Good Standing)(Fernandes, Kalikoonalani) (Filed on 7/7/2025) (Entered: 07/07/2025)	July 7, 2025	July 7, 2025 PACER
30	MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 328, receipt number ACANDC-20863176.) filed by State of Hawaii. (Attachments: # 1 HI Certificate of Good Standing)(Day, David) (Filed on 7/7/2025) (Entered: 07/07/2025)	July 7, 2025	July 7, 2025 PACER
31	MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 328, receipt number ACANDC-20863212.) filed by State of Arizona. (Salas, Alexa) (Filed on 7/7/2025) (Entered: 07/07/2025)	July 7, 2025	July 7, 2025 PACER
32	Order by Judge Vince Chhabria granting 28 Motion for Pro Hac Vice as to Mark Ladov. (bxs, COURT STAFF) (Filed on 7/7/2025)Any non-CM/ECF Participants have been served by First Class Mail to the addresses of record listed on the Notice of Electronic Filing (NEF) (Entered: 07/07/2025)	July 7, 2025	July 7, 2025 PACER
33	Order by Judge Vince Chhabria granting 29 Motion for Pro Hac Vice as to Kalikoonalani Fernandes. (bxs, COURT STAFF) (Filed on 7/7/2025)Any non-CM/ECF Participants have been served by First Class Mail to the addresses of record listed on the Notice of Electronic Filing (NEF) (Entered: 07/07/2025)	July 7, 2025	July 7, 2025 PACER
34	Order by Judge Vince Chhabria granting 30 Motion for Pro Hac Vice as to David Day. (bxs, COURT STAFF) (Filed on 7/7/2025)Any non-CM/ECF Participants have been served by First Class Mail to the addresses of record listed on the Notice of Electronic Filing (NEF) (Entered: 07/07/2025)	July 7, 2025	July 7, 2025 PACER
	Notice of Appearance/Substitution/Change/Withdrawal of Attorney	July 7, 2025	July 7, 2025 PACER
35	NOTICE of Appearance filed by Katherine J. Bies on behalf of State of Minnesota (Bies, Katherine) (Filed on 7/9/2025) (Entered: 07/09/2025)	July 9, 2025	July 9, 2025 PACER
36	MOTION for leave to appear in Pro Hac Vice ( Filing fee $ 328, receipt number ACANDC-20873135.) filed by State of Massachusetts. (Marks, Ethan) (Filed on 7/9/2025) (Entered: 07/09/2025)	July 9, 2025	July 9, 2025 PACER
37	Order by Judge Vince Chhabria granting 36 Motion for Pro Hac Vice as to Ethan Marks. (bxs, COURT STAFF) (Filed on 7/9/2025) (Entered: 07/09/2025)	July 9, 2025	July 9, 2025 PACER

Case: State of California v. U.S. Department of Health and Human Services

3:25-cv-05536 | U.S. District Court for the Northern District of California

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