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President Donald Trump listens to a question from a reporter as he meets with NATO Secretary General Mark Rutte in the Oval Office of the White House, Wednesday, Oct. 22, 2025, in Washington (AP Photo/Alex Brandon).
A federal judge in Rhode Island has ruled against the Trump administration’s attempt to withhold transportation funding from states that do not comply with federal immigration priorities.
In a decision delivered on Tuesday, Chief U.S. District Judge John McConnell addressed the core issue of the case: “Can the executive branch use federal transportation funding—amounting to billions of dollars—as leverage to enforce state cooperation with federal civil immigration enforcement?”
Over the course of 32 pages, Judge McConnell, an appointee of former President Barack Obama, explored the history and legal precedents relevant to the case. He concluded that the president does not possess such authority and criticized the Trump administration’s actions.
Judge McConnell stated, “The defendants have clearly exceeded their statutory authority, violated the Administrative Procedure Act, and disregarded established constitutional limits on federal funding conditions.” He emphasized that “the Constitution requires the Court to reject this unlawful conduct.”
The judge also noted that while Congress could potentially make federal transportation funding contingent on cooperation with federal civil immigration enforcement, there was no evidence of such legislative action. Thus, he concluded that the Department of Transportation did not have the extensive authority it claimed to impose conditions unrelated to its grant programs.
In April, Transportation Secretary Sean Duffy issued a warning to states that they must follow federal immigration law. Around the same time as the so-called “Duffy Directive,” the Department of Transportation (DOT) “began adding language to reflect the Duffy Directive’s position into grant agreements” — what has been referred to as the Immigration Enforcement Condition (IEC), as McConnell recounts.
A group of 20 states, including California, Connecticut, and Rhode Island, sued the Trump administration to halt the so-called “Duffy Directive,” and in June, McConnell granted a preliminary injunction, finding that they were “likely to succeed” in their argument that such a condition violates the Administrative Procedure Act (APA) — the federal statute governing the behavior of federal agencies — and the U.S. Constitution.
The Trump administration has argued, among other things, that the IEC was designed “with the stated goal of improving public safety,” suggesting the states are not entitled to federal funds when they plan to violate federal law.
McConnell dismissed this argument, calling it a “gimcrack defense.”
“The Court has disposed of Defendants’ nakedly misleading characterization of what the IEC requires,” he wrote.
The judge declared the IEC unlawful and ordered its language removed from all grant agreements administered by the Department of Transportation. He also prohibited the defendants from “attempting to condition federal transportation funding on State cooperation with federal civil immigration enforcement.”
Connecticut Attorney General William Tong celebrated the ruling.
“Donald Trump tried to condition billions of dollars in transportation funds on a series of irrational immigration demands,” Tong said. “It was dumb and dangerous, and we just beat him again in court. We need safe, functioning highways, railways and airways. That’s one of the most basic functions of government. The fact that Donald Trump would imperil that shows just how little he cares about the safety of American families.”
Law&Crime reached out to the DOT for comment.