Case: State of New York v. U.S. Department of Justice

1:25-cv-00345 | U.S. District Court for the District of Rhode Island

Filed Date: July 21, 2025

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Case Summary

This case challenged the revocation of various exemptions under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA). The PRWORA is part of the federal welfare system and governs the eligibility of noncitizens for Federal, State, and local public benefits. The statute provides definitions of "alien," "qualified alien," and "federal public benefit," and also provides exemptions for certain public benefits such as emergency medical care and short-term, in-kind emergency disaster relief. Under the PRWORA, the Attorney General is directed to “promulgate regulations requiring verification that a person applying for a Federal public benefit . . . is a qualified alien and is eligible to receive such benefit.” Following the enactment of the PRWORA, various agencies, such as the Department of Justice, the Department of Labor, the Department of Education, and the Department of Health and Human Services, promulgated regulations explaining the scope of the PRWORA as applied to the benefits provided by their agencies.

However, in July 2025, the DOJ, the DOL, the DOE, and the HHS revised their regulations, revoking many of the exemptions that they had promulgated earlier under the PRWORA. Under the new regulations, many federal benefits administered by these agencies become subject to PRWORA's requirements. The new requirements meant that many undocumented immigrants, who previously had access to some federal benefits under the agency exemptions, were no longer exempted, and therefore states that administered federal benefit programs were required to implement verification schemes to verify the status of benefit recipients, even if the programs previously did not require such verification.

On July 21, 2025, 20 states and the District of Columbia filed suit in the District Court for the District of Columbia against the DOJ, the DOL, the DOE, and the HHS. Represented by their state attorneys general, the plaintiff states claimed that the agencies' actions violated the Administrative Procedure Act (APA) by failing to engage in notice and comment, and by being arbitrary and capricious, and by being contrary to law. The states also argued that the regulations violated the Spending Clause by imposing conditions on federal funding that were unclear, by imposing conditions on the states that they did not have an opportunity to agree to, and by unconstitutionally coercing the states. The states asked the court to declare the agency regulations unlawful and to enjoin the defendants from enforcing them. The plaintiffs filed a motion for a preliminary injunction on the same day.

The case was assigned to District Judge Mary S. McElroy.

On July 30, the defendants filed a stipulation with the court, agreeing not to enforce the challenged notices against the plaintiff states until September 10, 2025. The defendants also stipulated that they would not ever enforce the notices based on conduct occurring in the plaintiff States before September 11, 2025; funds expended in the plaintiff States before September 11, 2025; or any other actions taken in reliance on this Stipulation before September 11, 2025.

ECF Number	Description	Date	Link Date / Link
1	COMPLAINT ( filing fee paid $ 405.00, receipt number ARIDC-2162815 ), filed by State of Rhode Island. (Attachments: # 1 Civil Cover Sheet)(Provazza, Stephen) (Entered: 07/21/2025) 1 Civil Cover Sheet View on PACER	July 21, 2025	July 21, 2025 Clearinghouse
2	MOTION for Preliminary Injunction filed by State of Rhode Island. Responses due by 8/4/2025. (Provazza, Stephen) (Entered: 07/21/2025)	July 21, 2025	July 21, 2025 RECAP
3	CASE OPENING NOTICE ISSUED (Simoncelli, Michael) (Entered: 07/21/2025)	July 21, 2025	July 21, 2025 PACER
4	DECLARATION re 2 MOTION for Preliminary Injunction by State of Rhode Island. (Attachments: # 1 Exhibit 1- DOJ PRWORA Notice, # 2 Exhibit 2- HHS PRWORA Notice, # 3 Exhibit 3 - ED PRWORA Notice, # 4 Exhibit 4 - TEGL 10-23 Change 2, DOL Notice, # 5 Exhibit 5 - HHS Final Regulatory Impact Analysis, # 6 Exhibit 6 - 1997 ED DCL, # 7 Exhibit 7 - 2024 DOL Guidance, # 8 Exhibit 8 - TEGL 19-16 Attachment II, # 9 Exhibit 9- Chart of Exhibits, # 10 Exhibit 10- CA Neary, # 11 Exhibit 11 - CA Chawla, # 12 Exhibit 12 - CA Hansen, # 13 Exhibit 13 - CA Kunins, # 14 Exhibit 14 - CA Miller, # 15 Exhibit 15- CA Jaime-Mileham, # 16 Exhibit 16- CA Thurmond, # 17 Exhibit 17- CA Brown, # 18 Exhibit 18- CO Ongart, # 19 Exhibit 19 - CO Folks, # 20 Exhibit 20- CO Becker, # 21 Exhibit 21- CT Navarretta, # 22 Exhibit 22- CT Hadler, # 23 Exhibit 23 -DC Matthews, # 24 Exhibit 24 - DC Boardman-Schroyer, # 25 Exhibit 25 - IL Durham, # 26 Errata 26 - IL Stevens, # 27 Exhibit 27 - IL Masinter, # 28 Exhibit 28 - IL Wortman, # 29 Exhibit 29 - IL Rollinson, # 30 Exhibit 30 - IL Sanders, # 31 Exhibit 31 - MA Jee, # 32 Exhibit 32 - MA Woo, # 33 Exhibit 33 - MA Mackinnon, # 34 Exhibit 34 - MA Boyle, # 35 Exhibit 35 - MD Meister, # 36 Exhibit 36 - MD Roth, # 37 Exhibit 37 - ME Gagne-Holmes, # 38 Exhibit 38 - ME McCoy, # 39 Exhibit 39 - MI Haywood, # 40 Exhibit 40 - MI Johnson, # 41 Exhibit 41 - MI Lyon-Callo, # 42 Exhibit 42 - MN Grumdahl, # 43 Exhibit 43 - NJ Winter, # 44 Exhibit 44 - NJ Schiff, # 45 Exhibit 5 - NJ Asaro-Angelo, # 46 Exhibit 46 - NJ Adelman, # 47 Exhibit 47 - NM Lafferty, # 48 Exhibit 48 - NM Gonzales, # 49 Exhibit 49 - NM Nair (First), # 50 Exhibit 50 - NM Nair (Second), # 51 Exhibit 51 - NY Rosen, # 52 Exhibit 52 - NY Meyers-Ruff, # 53 Exhibit 53 - NY Marton, # 54 Exhibit 54 - NY Heslin, # 55 Exhibit 55 - NY Orr, # 56 Exhibit 56 - NY Chisholm, # 57 Exhibit 57 - NY Morris-Groves, # 58 Exhibit 58 - OR Chatterjee, # 59 Exhibit 59 - OR Shore, # 60 Exhibit 60 - OR Cannon, # 61 Exhibit 61 - OR Clarke, # 62 Exhibit 62 - OR Weber, # 63 Exhibit 63 - RI Giron, # 64 Exhibit 64 - RI Weldon, # 65 Exhibit 65 - RI Martin, # 66 Exhibit 66 - WA Guertin-Anderson, # 67 Exhibit 67 - WA Khan, # 68 Exhibit 68 - WA Adams, # 69 Exhibit 69 - WA Roberts, # 70 Exhibit 70 - WA Mathis, # 71 Exhibit 71 - WA Kirschbaum, # 72 Exhibit 72 - WI Standridge, # 73 Exhibit 73 - AZ Flores, # 74 Exhibit 74 - VT Saunders, # 75 Exhibit 5 - VT Hawes, # 76 Exhibit 76 - VT Arel)(Provazza, Stephen) (Entered: 07/21/2025) 1 Exhibit 1- DOJ PRWORA Notice View on RECAP 2 Exhibit 2- HHS PRWORA Notice View on RECAP 3 Exhibit 3 - ED PRWORA Notice View on RECAP 4 Exhibit 4 - TEGL 10-23 Change 2, DOL Notice View on RECAP 5 Exhibit 5 - HHS Final Regulatory Impact Analysis View on RECAP 6 Exhibit 6 - 1997 ED DCL View on RECAP 7 Exhibit 7 - 2024 DOL Guidance View on RECAP 8 Exhibit 8 - TEGL 19-16 Attachment II View on RECAP 9 Exhibit 9- Chart of Exhibits View on RECAP 10 Exhibit 10- CA Neary View on RECAP 11 Exhibit 11 - CA Chawla View on RECAP 12 Exhibit 12 - CA Hansen View on RECAP 13 Exhibit 13 - CA Kunins View on RECAP 14 Exhibit 14 - CA Miller View on RECAP 15 Exhibit 15- CA Jaime-Mileham View on RECAP 16 Exhibit 16- CA Thurmond View on RECAP 17 Exhibit 17- CA Brown View on RECAP 18 Exhibit 18- CO Ongart View on PACER 19 Exhibit 19 - CO Folks View on PACER 20 Exhibit 20- CO Becker View on PACER 21 Exhibit 21- CT Navarretta View on PACER 22 Exhibit 22- CT Hadler View on PACER 23 Exhibit 23 -DC Matthews View on PACER 24 Exhibit 24 - DC Boardman-Schroyer View on PACER 25 Exhibit 25 - IL Durham View on PACER 26 Errata 26 - IL Stevens View on PACER 27 Exhibit 27 - IL Masinter View on PACER 28 Exhibit 28 - IL Wortman View on PACER 29 Exhibit 29 - IL Rollinson View on PACER 30 Exhibit 30 - IL Sanders View on PACER 31 Exhibit 31 - MA Jee View on PACER 32 Exhibit 32 - MA Woo View on PACER 33 Exhibit 33 - MA Mackinnon View on PACER 34 Exhibit 34 - MA Boyle View on PACER 35 Exhibit 35 - MD Meister View on PACER 36 Exhibit 36 - MD Roth View on PACER 37 Exhibit 37 - ME Gagne-Holmes View on PACER 38 Exhibit 38 - ME McCoy View on PACER 39 Exhibit 39 - MI Haywood View on PACER 40 Exhibit 40 - MI Johnson View on PACER 41 Exhibit 41 - MI Lyon-Callo View on PACER 42 Exhibit 42 - MN Grumdahl View on PACER 43 Exhibit 43 - NJ Winter View on PACER 44 Exhibit 44 - NJ Schiff View on PACER 45 Exhibit 5 - NJ Asaro-Angelo View on PACER 46 Exhibit 46 - NJ Adelman View on PACER 47 Exhibit 47 - NM Lafferty View on PACER 48 Exhibit 48 - NM Gonzales View on PACER 49 Exhibit 49 - NM Nair (First) View on PACER 50 Exhibit 50 - NM Nair (Second) View on PACER 51 Exhibit 51 - NY Rosen View on RECAP 52 Exhibit 52 - NY Meyers-Ruff View on RECAP 53 Exhibit 53 - NY Marton View on RECAP 54 Exhibit 54 - NY Heslin View on RECAP 55 Exhibit 55 - NY Orr View on RECAP 56 Exhibit 56 - NY Chisholm View on RECAP 57 Exhibit 57 - NY Morris-Groves View on RECAP 58 Exhibit 58 - OR Chatterjee View on PACER 59 Exhibit 59 - OR Shore View on PACER 60 Exhibit 60 - OR Cannon View on PACER 61 Exhibit 61 - OR Clarke View on PACER 62 Exhibit 62 - OR Weber View on PACER 63 Exhibit 63 - RI Giron View on PACER 64 Exhibit 64 - RI Weldon View on PACER 65 Exhibit 65 - RI Martin View on PACER 66 Exhibit 66 - WA Guertin-Anderson View on PACER 67 Exhibit 67 - WA Khan View on PACER 68 Exhibit 68 - WA Adams View on PACER 69 Exhibit 69 - WA Roberts View on PACER 70 Exhibit 70 - WA Mathis View on PACER 71 Exhibit 71 - WA Kirschbaum View on PACER 72 Exhibit 72 - WI Standridge View on PACER 73 Exhibit 73 - AZ Flores View on PACER 74 Exhibit 74 - VT Saunders View on PACER 75 Exhibit 5 - VT Hawes View on PACER 76 Exhibit 76 - VT Arel View on PACER	July 21, 2025	July 21, 2025 PACER
5	Summons Request filed by State of Rhode Island. (Attachments: # 1 Summons - Bondi, # 2 Summons - HHS, # 3 Summons - Kennedy, # 4 Summons - Dept. of Ed., # 5 Summons - McMahon, # 6 Summons - Dept. of Labor, # 7 Summons - Chavez-DeRemer)(Provazza, Stephen) (Entered: 07/21/2025)	July 21, 2025	July 21, 2025 PACER
6	Summons Issued as to Pamela Bondi, Lori Chavez-DeRemer, Robert F. Kennedy, Jr., Linda McMahon, U.S. Department of Education, U.S. Department of Justice, U.S. Department of Labor, US Department of Health and Human Services. (Attachments: # 1 Summons Issued - Bondi, # 2 Summons Issued - U.S. Dept. Health & Human Services, # 3 Summons Issued - Kennedy, Jr., # 4 Summons Issued - U.S. Dept. of Education, # 5 Summons Issued - McMahon, # 6 Summons Issued - U.S. Dept. of Labor, # 7 Summons Issued - Chavez-DeRemer) (Gonzalez Gomez, Viviana) (Entered: 07/21/2025)	July 21, 2025	July 21, 2025 PACER
	Case Assigned/Reassigned	July 21, 2025	July 21, 2025 PACER
	Case assigned to District Judge Mary S. McElroy and Magistrate Judge Patricia A. Sullivan. (Simoncelli, Michael)	July 21, 2025	July 21, 2025 PACER
10	NOTICE of Appearance by Rabia Muqaddam on behalf of State of New York (Muqaddam, Rabia) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
11	NOTICE of Appearance by Jessica Ranucci on behalf of State of New York (Ranucci, Jessica) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
12	NOTICE of Appearance by Ryan P. Kane on behalf of State of Vermont (Kane, Ryan) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
13	NOTICE of Appearance by Zoe Levine on behalf of State of New York (Levine, Zoe) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
14	SUMMONS Returned Executed by State of Rhode Island. All Defendants. (Attachments: # 1 Bondi - Signed Summons, # 2 HHS - Signed Summons, # 3 Kennedy - Signed Summons, # 4 Dept. of Education - Signed Summons, # 5 McMahon - Signed Summons, # 6 Dept. of Labor - Signed Summons, # 7 Chavez-DeRemer - Signed Summons)(Provazza, Stephen) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
15	NOTICE of Appearance by Mark Noferi on behalf of State of New Mexico (Noferi, Mark) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
16	NOTICE of Appearance by David Moskowitz on behalf of State of Colorado (Moskowitz, David) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
17	NOTICE of Appearance by Sarah North on behalf of State of Illinois (North, Sarah) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
18	NOTICE of Appearance by Mitchell Reich on behalf of District of Columbia (Reich, Mitchell) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
19	NOTICE of Appearance by Holly Frances Balsley Berlin on behalf of State of Illinois (Berlin, Holly) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
20	NOTICE of Appearance by Neli Nima Palma on behalf of State of California (Palma, Neli) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
21	NOTICE of Appearance by Kalikoonalani Diara Fernandes on behalf of State of Hawai'i (Fernandes, Kalikoonalani) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
22	NOTICE of Appearance by David Dana Day on behalf of State of Hawai'i (Day, David) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
23	NOTICE of Appearance by Kalikoonalani Diara Fernandes on behalf of State of Hawai'i (Fernandes, Kalikoonalani) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
24	NOTICE of Appearance by David Dana Day on behalf of State of Hawai'i (Day, David) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
25	NOTICE of Appearance by Hayleigh S Crawford on behalf of State of Arizona (Crawford, Hayleigh) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
26	NOTICE of Appearance by Mary M. Curtin on behalf of State of Arizona (Curtin, Mary) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
27	NOTICE of Appearance by Andrew R.W. Hughes on behalf of State of Washington (Hughes, Andrew) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
28	NOTICE of Appearance by Zane Muller on behalf of State of Washington (Muller, Zane) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
29	NOTICE of Appearance by Cristina Sepe on behalf of State of Washington (Sepe, Cristina) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
30	NOTICE of Appearance by Benjamin M. Seel on behalf of State of Washington (Seel, Benjamin) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
7	NOTICE of Appearance by Sarah Rice on behalf of State of Rhode Island (Rice, Sarah) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
8	NOTICE of Appearance by Neil Giovanatti on behalf of State of Michigan (Giovanatti, Neil) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
9	NOTICE of Appearance by Bryan William Beach on behalf of State of Michigan (Beach, Bryan) (Entered: 07/22/2025)	July 22, 2025	July 22, 2025 PACER
	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 District Judge Mary S. McElroy on 7/22/2025. (Potter, Carrie)	July 22, 2025	July 22, 2025 PACER
	Order	July 22, 2025	July 22, 2025 PACER
31	NOTICE of Appearance by Patricia Ellen McCooey on behalf of State of Connecticut (McCooey, Patricia) (Entered: 07/23/2025)	July 23, 2025	July 23, 2025 PACER
32	NOTICE of Appearance by Panchalam Seshan Srividya on behalf of State of California (Srividya, Panchalam) (Entered: 07/23/2025)	July 23, 2025	July 23, 2025 PACER
33	NOTICE of Appearance by Faye B. Hipsman on behalf of State of Wisconsin (Hipsman, Faye) (Entered: 07/23/2025)	July 23, 2025	July 23, 2025 PACER
34	NOTICE of Appearance by Meghan Musso on behalf of State of New Jersey (Musso, Meghan) (Entered: 07/24/2025)	July 24, 2025	July 24, 2025 PACER
35	NOTICE of Appearance by Brendan Kreckel on behalf of State of Maine (Kreckel, Brendan) (Entered: 07/24/2025)	July 24, 2025	July 24, 2025 PACER
36	NOTICE of Appearance by Coby Howell on behalf of State of Oregon (Howell, Coby) (Entered: 07/24/2025)	July 24, 2025	July 24, 2025 PACER

Case: State of New York v. U.S. Department of Justice

1:25-cv-00345 | U.S. District Court for the District of Rhode Island

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