ARTICLE
13 March 2025

District Court Orders Trump Administration To Release Federal Funding To States And Enjoins Implementation Of Federal Funding Freeze

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Duane Morris LLP

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On March 6, 2025, Judge John J. McConnell of the United States District Court for the District of Rhode Island granted the Motion for Preliminary Injunction sought by 22 state attorneys general and the Attorney General for the District of Columbia challenging the Trump Administration's "pause" or "freeze" of grant funding payments.
United States Food, Drugs, Healthcare, Life Sciences

On March 6, 2025, Judge John J. McConnell of the United States District Court for the District of Rhode Island granted the Motion for Preliminary Injunction sought by 22 state attorneys general and the Attorney General for the District of Columbia challenging the Trump Administration's "pause" or "freeze" of grant funding payments. The Court, ordered the Trump Administration to "release and transmit any disbursements to the States on awarded grants, executed contracts or other executed financial obligations that were paused on the grounds of the OMB Directive" and other related Executive Orders. In his 45-page order, Judge McConnell held that the Trump Administration's freeze on federal funding "fundamentally undermines" the separation of powers.

In support of their motion, the state attorneys general presented evidence of the widespread effects of the federal funding freeze, which they said has impacted "nearly all aspects of the States' governmental operations" and has inhibited the States' "ability to administer vital services to their residents." These harms, they argued, are a direct result of the efforts taken by the Trump Administration to withhold federal funds and implement the federal funding freeze.

According to Judge McConnell, "It is so obvious that it almost need not be stated that when money is obligated and therefore expected (particularly money that has been spent and reimbursement is sought) and is not paid as promised, harm follows—debt is incurred, debt is unpaid, essential health and safety services stop, and budgets are upended. And when there is no end in sight to the Defendants' funding freeze, that harm is amplified because those served by the expected but frozen funds have no idea when the promised monies will flow again." The order specifies numerous examples of harm, including the impact on childcare programs, education, healthcare, law enforcement and public safety agencies, job training and unemployment, and transportation infrastructure.

The order enjoins the Trump Administration from reissuing or implementing the OMB Directive with respect to the disbursement of federal funds, and from pausing, freezing, blocking, or otherwise impeding the disbursement of federal funds to the states.

The Court stated that its ruling comes after a "litany of struggles experienced [by the States] in the last seven weeks" caused by the Trump Administration's continued attempts to implement the funding freeze, despite the Court's two previous orders against implementation. On January 31, 2025, Judge McConnell granted the states attorneys general a temporary restraining order (TRO), and on February 10, 2025, he entered an order to enforce the TRO in light of evidence that the States were still being denied access to the federal funds.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.

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