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By Peter Aitken and Sonam Sheth
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A federal judge in Rhode Island on Thursday ruled against the Trump administration's plan to condition transportation funding for states across the country on whether they cooperated with federal immigration authorities, saying that the plan violates the Constitution.
The Context
The Trump administration has cracked down on immigration enforcement since President Donald Trump took office, including by targeting sanctuary cities and states who limit their cooperation with federal immigration authorities.
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As part of that effort, Secretary of Transportation Sean Duffy in April issued the "Duffy directive," which requires recipients of transportation grants to cooperate with Immigration and Customs Enforcement operations or lose out on federal funding for transportation initiatives. The DOT called the stipulation an Immigration Enforcement Condition (IEC).
What To Know
Twenty U.S. states sued the Trump administration over Duffy's April directive, arguing that it ran afoul of the Constitution and violated the Administrative Procedures Act (APA), which governs how federal agencies create and enforce regulations.
The plaintiffs asked U.S. District Judge John J. McConnell Jr. for an immediate injunction, which the judge granted on Thursday.
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"The IEC, backed by the Duffy Directive, is arbitrary and capricious in its scope
and lacks specificity in how the States are to cooperate on immigration enforcement in exchange for Congressionally appropriated transportation dollars–grant money that the States rely on to keep their residents safely and efficiently on the road, in the sky, and on the rails," the judge wrote.
McConnell, who was appointed by former President Barack Obama, added that the conditions would violate the Spending Clause as well, as the IEC is "not at all reasonably related to the transportation funding program grants whose statutorily articulated purposes are for the maintenance and safety" of the various transit apparatuses across the country.
The court issued its order ahead of a June 20 deadline for applicants to file for certain grants, all of which would have included language from Duffy's directive.
Duffy issued a statement on the ruling after this story was published, saying, "I directed states who want federal DOT money to comply with federal immigration laws. But, no surprise, an Obama-appointed judge has ruled that states can openly defy our federal immigration laws."
"This is judicial activism pure & simple and I will continue to fight in the courts," the transportation secretary added.
What People Are Saying
Judge John J. McConnell Jr. wrote in his ruling: "The Government does not cite to any plausible connection between cooperating with ICE enforcement and the congressionally approved purposes of the Department of Transportation. Under the Defendants' position, the Executive would be allowed to place any conditions it chose on congressionally appropriated funds, even when it would be entirely unrelated to the Department's purpose. Such is not how the three equal branches of government are allowed to operate under our Constitution."
New York Attorney General Letitia James, who was one of the plaintiffs in the lawsuit, wrote on X (formerly Twitter): "We just won a court order blocking @USDOT's illegal attempt to tie transportation funding to immigration enforcement. We will keep fighting to protect our immigrant communities and ensure our roads, airports, and transit systems get the support they need."
What Happens Next
The Trump administration will likely appeal McConnell's ruling.
Update 6/19/25, 7:41 p.m. ET: This article has been updated with additional information.
Update 6/20/25, 1:01 p.m. ET: This article has been updated with additional information.
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