State of Oklahoma v. HHS, 107 F.4th 1209

Congress enacted Title X to fund state and local family planning projects, delegating eligibility requirements to the Department of Health and Human Services (HHS).
HHS required Title X recipients, including Oklahoma, to provide nondirective counseling and referrals for all family-planning options, including abortion.
After Dobbs v. Jackson Women's Health Organization, Oklahoma raised concerns about state law prohibiting abortion referrals, proposed changes, but ultimately refused to provide required information (a national hotline) as a workaround suggested by HHS.
HHS terminated Oklahoma’s Title X grant due to noncompliance, and Oklahoma sought a preliminary injunction to prevent the reallocation of funds during litigation.
The district court denied the injunction, finding Oklahoma was unlikely to succeed on the merits; Oklahoma appealed, raising constitutional, statutory (Weldon Amendment), and administrative law arguments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Congress's Spending Power / Delegation	Congress improperly delegated ambiguous eligibility condition-setting to HHS, violating the spending clause.	HHS had clear statutory authority to set such requirements; Oklahoma accepted terms knowingly and voluntarily.	Court found Congress's delegation was clear; no Spending Clause violation.
Weldon Amendment Violation	HHS discriminated against Oklahoma for refusing to refer for abortions, violating Weldon Amendment protections.	Proposed sharing of a national call-in number was neutral information, not a referral "for" abortion; no discrimination.	Providing the call-in number was not referral for abortion; no likely Weldon Amendment violation.
Arbitrary and Capricious Agency Action	HHS’s termination was arbitrary, capricious, inconsistent with Title X, and in conflict with state law.	HHS’s actions followed statutory/regulatory authority and considered relevant factors, including recent legal changes.	HHS did not act arbitrarily or capriciously; conditions and interpretations were reasonable.
Preliminary Injunction Standard (Likelihood of Success)	Oklahoma claimed likely to succeed on merits, face irreparable harm, and public interest supports injunction.	HHS focused on Oklahoma's failure to show likelihood of success on the merits.	District court did not abuse its discretion in denying injunction based on low likelihood of Oklahoma's success.

Rust v. Sullivan, 500 U.S. 173 (1991) (upheld HHS authority to set counseling/referral conditions for Title X in light of statutory ambiguity)
Bennett v. Kentucky Dep't of Educ., 470 U.S. 656 (1985) (congressional delegation to agencies can satisfy spending power's clarity requirement)
Pennhurst State Sch. & Hosp. v. Halderman, 451 U.S. 1 (1981) (federal grant conditions must be unambiguous and voluntarily accepted)
South Dakota v. Dole, 483 U.S. 203 (1987) (Congress may condition federal funds on compliance with federal directives)
Diné Citizens Against Ruining Our Env’t v. Jewell, 839 F.3d 1276 (10th Cir. 2016) (preliminary injunction standards and review)