Trump Immigration Conditions on Disaster Funds Blocked by Judge

The Trump administration can’t withhold disaster-relief grants to states that don’t promise to assist with federal immigration enforcement, a federal judge ruled Wednesday.

The Department of Homeland Security “engaged in a wholly under-reasoned and arbitrary process” in putting immigration-related conditions on the federal funding, wrote Judge William Smith of the US District Court for the District of Rhode Island.

Smith permanently blocked enforcement of the grant conditions, granting summary judgment to a coalition of states including Illinois, California, and New York.

The states sued in May, alleging the new strings attached to emergency-preparedness funds were illegal. The administration wanted grant recipients to certify they don’t “operate any program that benefits illegal immigrants or incentivizes illegal immigration” and promise to “honor requests for cooperation” in immigration enforcement.

The conditions were imposed to comply with an executive order calling for cutting funds to so-called “sanctuary” jurisdictions.

But in court, the administration “made no attempt to claim that it examined the relevant data or articulated a fact-based reason for its actions,” and gave no “actual explanation of why it is necessary to attach sweeping immigration conditions to all the grants at issue here,” Smith wrote, finding the conditions “arbitrary and capricious” in violation of the Administrative Procedure Act and unconstitutional under the spending clause.

The states risked losing billions in essential public-safety funding if they didn’t comply with “hopelessly vague” conditions that were unlawfully coercive, Smith wrote.

“Denying such funding if states refuse to comply with vague immigration requirements leaves them with no meaningful choice, particularly where state budgets are already committed,” he wrote.

The case is Illinois v. Federal Emergency Management Agency, D.R.I., No. 1:25-cv-00206, order 9/24/25.