State of California v. United States Department of Transportation
1:25-cv-00208
D.R.I.Jun 19, 2025Background
- Twenty states sued the U.S. Department of Transportation (DOT) and Secretary Sean Duffy over a new "Immigration Enforcement Condition" (IEC) requiring state recipients of federal transportation funds to cooperate with federal immigration enforcement.
- The IEC was implemented by the "Duffy Directive" in April 2025 and made cooperation with ICE and other Department of Homeland Security components a prerequisite for receiving DOT grants.
- Plaintiffs allege the directive unlawfully conditions transportation funding, which was appropriated by Congress solely for transportation purposes, on unrelated immigration enforcement cooperation.
- States argue that the condition violates the Administrative Procedure Act (APA), the Spending Clause of the U.S. Constitution, and exceeds DOT’s statutory authority.
- The court considered granting a preliminary injunction, applying the four-factor test: likelihood of success on the merits, irreparable harm, balance of equities, and public interest.
- The court found a strong likelihood of success for the states, risk of irreparable harm if the condition is enforced, and that both balance of equities and the public interest favored injunctive relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction | District court is proper; claims are statutory and constitutional, not contractual. | Exclusive jurisdiction lies in federal appellate court or Court of Claims under Tucker Act. | Jurisdiction proper in district court; Tucker Act does not apply. |
| Statutory Authority (Ultra Vires) | DOT lacks authority to impose immigration conditions on transportation funding. | IEC is within executive authority and properly conditions federal funds. | DOT acted outside statutory authority; executive cannot impose IEC on transportation funds. |
| Spending Clause | IEC is unrelated to transportation funding’s purpose; is coercive and vague. | Congress can attach conditions to federal funds; IEC ensures legal compliance. | IEC violates Spending Clause; lacks nexus to transportation and is impermissibly coercive. |
| Arbitrary & Capricious (APA) | IEC is arbitrary, lacks clear standards and justification, exceeds agency authority. | Policy sets clear requirements; aligns with agency goals. | IEC imposition via Duffy Directive is arbitrary and capricious under APA. |
Key Cases Cited
- Loan Syndications & Trading Ass’n v. S.E.C., [818 F.3d 716] (D.C. Cir. 2016) (clarifies limits on jurisdictional statutes regarding federal agency orders)
- Bowen v. Massachusetts, [487 U.S. 879] (1988) (equitable relief under APA is not a claim for money damages subject to the Tucker Act)
- City of Providence v. Barr, [954 F.3d 23] (1st Cir. 2020) (agency cannot impose grant conditions without congressional authorization)
- K–Mart Corp. v. Oriental Plaza, Inc., [875 F.2d 907] (1st Cir. 1989) (district courts' discretion in assessing irreparable harm and granting injunctive relief)
- Ross-Simons of Warwick, Inc. v. Baccarat, Inc., [102 F.3d 12] (1st Cir. 1996) (relationship between likelihood of success and irreparable harm in injunction analysis)