Case: State of New Jersey v. United States Department of Justice

1:25-cv-00404 | U.S. District Court for the District of Rhode Island

Filed Date: Aug. 18, 2025

Case Ongoing

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Case Summary

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…

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.

This case is ongoing. 

Summary Authors

Victoria Tan (8/22/2025)

People

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/


Judge(s)
Attorney for Plaintiff

Abraham, Stanley William (Rhode Island)

Castelli, Thomas H. (Rhode Island)

Chien, Marsha (Rhode Island)

Day, David Dana (Rhode Island)

Duraiswamy, Shankar (Rhode Island)

Attorney for Defendant

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Documents in the Clearinghouse

Document
1

1:25-cv-00404

Complaint for Declaratory and Injunctive Relief

Aug. 18, 2025

Aug. 18, 2025

Complaint

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/71135488/state-of-new-jersey-v-united-states-department-of-justice/

Last updated Oct. 16, 2025, 10:12 p.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT ( filing fee paid $ 405.00, receipt number ARIDC-2173180 ), filed by State of Rhode Island. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Civil Cover Sheet, # 5 Summons Request, # 6 Summons Request, # 7 Summons Request, # 8 Summons Request, # 9 Summons Request, # 10 Summons Request)(Giarrano, Leonard) (Entered: 08/18/2025)

1 Exhibit

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2 Exhibit

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3 Exhibit

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4 Civil Cover Sheet

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5 Summons Request

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6 Summons Request

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7 Summons Request

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8 Summons Request

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9 Summons Request

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10 Summons Request

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Aug. 18, 2025

Aug. 18, 2025

Clearinghouse
2

CASE OPENING NOTICE ISSUED (Hill, Cherelle) (Entered: 08/18/2025)

Aug. 18, 2025

Aug. 18, 2025

PACER
3

Summons Issued as to Pamela J. Bondi, Maureen Henneberg, Office for Victims of Crime, Office of Justice Programs, Katherine Darke Schmitt, United States Department of Justice (Attachments: # 1 Maureen Henneberg Summons, # 2 Office for Victims of Crime Summons, # 3 Office of Justice Programs Summons, # 4 Pamela J. Bondi Summons, # 5 United States Department of Justice Suumons)(Hill, Cherelle) (Entered: 08/18/2025)

Aug. 18, 2025

Aug. 18, 2025

PACER

Case Assigned/Reassigned

Aug. 18, 2025

Aug. 18, 2025

PACER

Case assigned to Chief Judge John J. McConnell, Jr. and Magistrate Judge Amy E. Moses. (Hill, Cherelle)

Aug. 18, 2025

Aug. 18, 2025

PACER
4

SUMMONS Returned Executed by State of Rhode Island. All Defendants. (Attachments: # 1 Signed Proof of Service (Pamela J. Bondi), # 2 Signed Proof of Service (OJP), # 3 Signed Proof of Service (Maureen Henneberg), # 4 Signed Proof of Service (OVC), # 5 Signed Proof of Service (Katherine Darke Schmitt))(Giarrano, Leonard) (Entered: 08/19/2025)

1 Signed Proof of Service (Pamela J. Bondi)

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2 Signed Proof of Service (OJP)

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3 Signed Proof of Service (Maureen Henneberg)

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4 Signed Proof of Service (OVC)

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5 Signed Proof of Service (Katherine Darke Schmitt)

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Aug. 19, 2025

Aug. 19, 2025

PACER

Order

Aug. 20, 2025

Aug. 20, 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 who 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 8/20/2025. (Jackson, Ryan)

Aug. 20, 2025

Aug. 20, 2025

PACER
10

NOTICE of Appearance by Delbert Tran on behalf of State of California (Tran, Delbert) (Entered: 08/21/2025)

Aug. 21, 2025

Aug. 21, 2025

PACER
11

NOTICE of Appearance by Luke Freedman on behalf of State of California (Freedman, Luke) (Entered: 08/21/2025)

Aug. 21, 2025

Aug. 21, 2025

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12

NOTICE of Appearance by Newton Knowles, III on behalf of State of California (Knowles, Newton) (Entered: 08/21/2025)

Aug. 21, 2025

Aug. 21, 2025

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NOTICE of Appearance by Joel Marrero on behalf of State of California (Marrero, Joel) (Entered: 08/21/2025)

Aug. 21, 2025

Aug. 21, 2025

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5

NOTICE of Appearance by Ian Liston on behalf of State of Delaware (Liston, Ian) (Entered: 08/21/2025)

Aug. 21, 2025

Aug. 21, 2025

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6

NOTICE of Appearance by Vanessa L. Kassab on behalf of State of Delaware (Kassab, Vanessa) (Entered: 08/21/2025)

Aug. 21, 2025

Aug. 21, 2025

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7

NOTICE of Appearance by Rosanna E. Gibson on behalf of State of Delaware (Gibson, Rosanna) (Entered: 08/21/2025)

Aug. 21, 2025

Aug. 21, 2025

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8

NOTICE of Appearance by Lee Sherman on behalf of State of California (Sherman, Lee) (Entered: 08/21/2025)

Aug. 21, 2025

Aug. 21, 2025

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9

NOTICE of Appearance by Deylin O Thrift-Viveros on behalf of State of California (Thrift-Viveros, Deylin) (Entered: 08/21/2025)

Aug. 21, 2025

Aug. 21, 2025

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14

NOTICE of Appearance by Jonathan T. Rose on behalf of State of Vermont (Rose, Jonathan) (Entered: 08/22/2025)

Aug. 22, 2025

Aug. 22, 2025

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NOTICE of Appearance by Shankar Duraiswamy on behalf of State of New Jersey (Duraiswamy, Shankar) (Entered: 08/22/2025)

Aug. 22, 2025

Aug. 22, 2025

PACER
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NOTICE of Appearance by Heidi Joya on behalf of State of California (Joya, Heidi) (Entered: 08/22/2025)

Aug. 22, 2025

Aug. 22, 2025

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NOTICE of Appearance by Mayur Prasad Saxena on behalf of State of New Jersey (Saxena, Mayur) (Entered: 08/22/2025)

Aug. 22, 2025

Aug. 22, 2025

PACER
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NOTICE of Appearance by Zoe Levine on behalf of State of New York (Levine, Zoe) (Entered: 08/23/2025)

Aug. 23, 2025

Aug. 23, 2025

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19

NOTICE of Appearance by Natalie Moreland Villalon on behalf of All Defendants (Moreland Villalon, Natalie) (Entered: 08/25/2025)

Aug. 25, 2025

Aug. 25, 2025

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20

NOTICE of Appearance by Hannah Vail on behalf of Commonwealth of Massachusetts (Vail, Hannah) (Entered: 08/25/2025)

Aug. 25, 2025

Aug. 25, 2025

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21

NOTICE of Appearance by Natasha Korgaonkar on behalf of State of New York (Korgaonkar, Natasha) (Entered: 08/25/2025)

Aug. 25, 2025

Aug. 25, 2025

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NOTICE of Appearance by David Moskowitz on behalf of State of Colorado (Moskowitz, David) (Entered: 08/26/2025)

Aug. 26, 2025

Aug. 26, 2025

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NOTICE of Appearance by John S. Pallas on behalf of State of Michigan (Pallas, John) (Entered: 08/27/2025)

Aug. 27, 2025

Aug. 27, 2025

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24

NOTICE of Appearance by Stanley William Abraham, III on behalf of State of Maine (Abraham, Stanley) (Entered: 08/27/2025)

Aug. 27, 2025

Aug. 27, 2025

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NOTICE of Appearance by Neil Giovanatti on behalf of State of Michigan (Giovanatti, Neil) (Entered: 08/27/2025)

Aug. 27, 2025

Aug. 27, 2025

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NOTICE of Appearance by Thomas H. Castelli on behalf of State of Oregon (Castelli, Thomas) (Entered: 08/29/2025)

Aug. 29, 2025

Aug. 29, 2025

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NOTICE of Appearance by Heidi Parry Stern on behalf of State of Nevada (Stern, Heidi) (Entered: 09/03/2025)

Sept. 3, 2025

Sept. 3, 2025

PACER
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NOTICE of Appearance by Kalikoonalani Diara Fernandes on behalf of State of Hawai'i (Fernandes, Kalikoonalani) (Entered: 09/03/2025)

Sept. 3, 2025

Sept. 3, 2025

PACER
29

NOTICE of Appearance by David Dana Day on behalf of State of Hawai'i (Day, David) (Entered: 09/03/2025)

Sept. 3, 2025

Sept. 3, 2025

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30

NOTICE of Appearance by Michael M. Tresnowski on behalf of State of Illinois (Tresnowski, Michael) (Entered: 09/04/2025)

Sept. 4, 2025

Sept. 4, 2025

PACER
31

NOTICE of Appearance by Robert Henry Weaver on behalf of State of Illinois (Weaver, Robert) (Entered: 09/05/2025)

Sept. 5, 2025

Sept. 5, 2025

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NOTICE of Appearance by Marsha Chien on behalf of State of Washington (Chien, Marsha) (Entered: 09/09/2025)

Sept. 9, 2025

Sept. 9, 2025

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NOTICE of Appearance by Tyler S. Roberts on behalf of State of Washington (Roberts, Tyler) (Entered: 09/09/2025)

Sept. 9, 2025

Sept. 9, 2025

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NOTICE of Appearance by Benjamin M. Seel on behalf of State of Washington (Seel, Benjamin) (Entered: 09/09/2025)

Sept. 9, 2025

Sept. 9, 2025

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NOTICE of Appearance by Cristina Sepe on behalf of State of Washington (Sepe, Cristina) (Entered: 09/09/2025)

Sept. 9, 2025

Sept. 9, 2025

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36

NOTICE of Appearance by Benjamin Daniel Liebowitz on behalf of State of New York (Liebowitz, Benjamin) (Entered: 09/12/2025)

Sept. 12, 2025

Sept. 12, 2025

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37

NOTICE of Appearance by Colin T. Roth on behalf of State of Wisconsin (Roth, Colin) (Entered: 09/26/2025)

Sept. 26, 2025

Sept. 26, 2025

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38

NOTICE of Appearance by Ashley H. Meskill on behalf of State of Connecticut (Meskill, Ashley) (Entered: 09/30/2025)

Sept. 30, 2025

Sept. 30, 2025

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39

Stay

Oct. 15, 2025

Oct. 15, 2025

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Case Details

State / Territory: Rhode Island

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):

State Plaintiff

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):

Jurisdiction-wide

Facility Type(s):

Government-run

Case Details

Causes of Action:

Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.

Constitutional Clause(s):

Spending/Appropriations Clauses

Separation of Powers

Available Documents:

Trial Court Docket

Complaint (any)

Outcome

Prevailing Party: None Yet / None

Nature of Relief:

None yet

Source of Relief:

None yet

Issues

General/Misc.:

Funding

Government services

Public assistance grants

Presidential/Gubernatorial Authority:

Commandeering