Filed Date: Aug. 18, 2025
Case Ongoing
Clearinghouse coding complete
The Victims of Crime Act (VOCA) was enacted by Congress in 1984 after a 1982 report from President Ronald Reagan's Task Force on Victims of Crime concluded that the "neglect of crime victims is a national disgrace". VOCA created a series of grant programs to help states provide critical resources and services to victims and survivors of crime, such as emergency shelter, sexual assault forensic exams, medical expenses, lost wages, and counseling. The intent was to provide direct compensation and service programs with minimal bureaucratic "strings attached" to support inadequately funded state and local victim assistance programs. The Act also created the Crime Victims Fund, which is financed by penalties and fees from federal offenders, not from taxpayers.
In July 2025, the Office for Victims of Crime (OVC), an agency within the U.S. Department of Justice (DOJ), attempted to impose new immigration enforcement conditions on federal grants provided to states under VOCA. This case challenges those conditions.
On August 18, 2025, several states and the District of Columbia filed this lawsuit in the U.S. District Court for the District of Rhode Island against the U.S. Department of Justice (DOJ); the U.S. Attorney General; the Office of Justice Programs (OJP) and its Acting Assistant Attorney General; and the Office for Victims of Crime (OVC) and its Acting Director. The plaintiffs alleged that the defendants’ actions violated the Administrative Procedure Act, the Separation of Powers, the Spending Clause, and were ultra vires. Represented by their Attorneys General, the plaintiffs sought declaratory and injunctive relief to enjoin the defendants from implementing or enforcing the conditions on the FY 2024 VOCA victim assistance grants. Judge John James McConnell Jr. presides over the case.
The plaintiffs argued that the conditions were unlawful because they lacked statutory authorization and were arbitrary and capricious under the Administrative Procedure Act, as they failed to account for states’ reliance interests or the conditions’ adverse impact on victims. They further contended that the conditions violated the Spending Clause, being unrelated to VOCA’s purpose, impermissibly ambiguous, and coercive in forcing states to forfeit either critical funding or their sovereign control over local resources. Additionally, the plaintiffs raised Separation of Powers and ultra vires claims, asserting that the DOJ and OVC had exceeded their statutory authority. They maintained that Congress, not federal agencies, retained the “power of the purse” and that nothing in VOCA or any other statute authorized the imposition of immigration-related funding conditions.
A month after filing the complaint, on October 3, 2025, New Jersey Attorney General Matthew J. Platkin and officials announced that the DOJ had agreed to “drop illegal conditions on this critical funding, which will ensure that advocacy services, sexual assault forensic exams, medical and funeral expenses, and other critical resources for victims of crimes will continue to be available.”
On October 15, 2025, the government filed for a stay of their deadline to file a motion to dismiss amid the government shutdown. The court denied the government's motion due to their obligations to continue their constitutional duties, but extended their deadline to respond to the complaint to December 19, 2025.
This case is ongoing.
Summary Authors
Victoria Tan (8/22/2025)
Maddy Ligon (10/21/2025)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/71135488/parties/state-of-new-jersey-v-united-states-department-of-justice/
Abraham, Stanley William (Rhode Island)
Castelli, Thomas H. (Rhode Island)
Chien, Marsha (Rhode Island)
Day, David Dana (Rhode Island)
Duraiswamy, Shankar (Rhode Island)
Abraham, Stanley William (Rhode Island)
Castelli, Thomas H. (Rhode Island)
Day, David Dana (Rhode Island)
Duraiswamy, Shankar (Rhode Island)
Fernandes, Kalikoonalani Diara (Rhode Island)
Giarrano, Leonard Giarrano (Rhode Island)
Gibson, Rosanna E. (Rhode Island)
Giovanatti, Neil (Rhode Island)
Kassab, Vanessa L. (Rhode Island)
Knowles, Newton Knowles (Rhode Island)
Korgaonkar, Natasha (Rhode Island)
Liebowitz, Benjamin Daniel (Rhode Island)
Meskill, Ashley H. (Rhode Island)
Moskowitz, David (Rhode Island)
Pallas, John S. (Rhode Island)
Roberts, Tyler S. (Rhode Island)
Rose, Jonathan T. (Rhode Island)
Saxena, Mayur Prasad (Rhode Island)
Seel, Benjamin M. (Rhode Island)
Stern, Heidi Parry (Rhode Island)
See docket on RECAP: https://www.courtlistener.com/docket/71135488/state-of-new-jersey-v-united-states-department-of-justice/
Last updated Nov. 29, 2025, 12:42 a.m.
State / Territory:
Case Type(s):
Presidential/Gubernatorial Authority
Special Collection(s):
Trump Administration 2.0: Challenges to the Government
Key Dates
Filing Date: Aug. 18, 2025
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
The District of Columbia and several states, including New Jersey, Rhode Island, California, Delaware, Illinois, Colorado, Connecticut, Hawaii, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Mexico, New York, Oregon, Vermont, Washington, and Wisconsin.
Plaintiff Type(s):
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
U.S. Department of Justice (- United States (national) -), Federal
U.S. Attorney General (- United States (national) -), Federal
Office of Justice Programs (- United States (national) -), Federal
Office of Justice Programs (- United States (national) -), Federal
Office for Victims of Crime (- United States (national) -), Federal
Defendant Type(s):
Facility Type(s):
Case Details
Causes of Action:
Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.
Constitutional Clause(s):
Spending/Appropriations Clauses
Other Dockets:
District of Rhode Island 1:25-cv-00404
Available Documents:
Outcome
Prevailing Party: None Yet / None
Relief Sought:
Relief Granted:
Source of Relief:
Issues
General/Misc.:
Presidential/Gubernatorial Authority: