On June 19, 2025, Chief U.S. District Judge John J. McConnell, Jr., of the District of Rhode Island granted a preliminary injunction to 20 states that had sued the U.S. Department of Transportation (DOT) and Secretary of Transportation Sean Duffy seeking to stop enforcement of an Immigration Enforcement Condition (IEC) that made transportation grants to the states conditional on their cooperation with federal officials in the enforcement of federal immigration law. We previously posted a blog about the states' lawsuit and a similar action against the U.S. Department of Homeland Security.
The states alleged that DOT has no statutory authority to impose the IEC as a requirement for federal funding that was appropriated for transportation; that the IEC violates the Spending Clause of the Constitution; and that, for various reasons, the DOT's actions violate the Administrative Procedure Act (APA). In granting the injunction, Judge McConnell held that the states were likely to succeed on the merits of some or all of their claims. Specifically, the Court held that:
- The Defendants' conduct violated the APA because they acted outside their statutory authority when Congress appropriated the funds for transportation purposes, not immigration purposes.
- The IEC is arbitrary and capricious and lacks specificity in how the states are to cooperate on immigration enforcement.
- The IEC violates the Spending Clause because "[t]he Government does not cite to any plausible connection between cooperating with ICE enforcement and the congressionally approved purposes of [the DOT]."
- The states will face irreparable and continuing harm–the loss of billions of dollars in federal transportation grant funds—if forced to agree to the IEC in order to receive the funds.
- The balance of the equities and the public interest favor granting the injunction, because without the injunction, there is a substantial risk that the states' citizens will face a significant disruption in transportation services.
The Court's order prohibits the Defendants from implementing or enforcing the IEC, or withholding or terminating federal funding based on the IEC. The Court also denied the government's request to stay the order pending appeal.
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