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 barred the Trump administration from withholding transportation funding to states based on their compliance with federal immigration priorities.
Chief U.S. District Judge John McConnell began his ruling on Tuesday with a simple synopsis of the situation: "At the heart of this case is the following question: can the executive branch leverage all federal transportation funding—totaling billions of dollars—to compel state cooperation with federal civil immigration enforcement?"
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Through 32 pages establishing the history of the case and relevant precedent, the Barack Obama appointee found that the president indeed cannot, and he issued harsh words for President Donald Trump's government in his conclusion.
"Defendants have blatantly overstepped their statutory authority, violated the [Administrative Procedure Act], and transgressed well-settled constitutional limitations on federal funding conditions," McConnell wrote. "The Constitution demands the Court set aside this lawless behavior."
The chief judge for the District of Rhode Island acknowledged that Congress could have attempted to "make federal transportation funding contingent on cooperation with federal civil immigration enforcement." But without evidence of it having done so, "the Court declines to find that [Department of Transportation] was vested with the sweeping power it asserts in setting a condition that is so obviously unrelated to the grant programs it administers."
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.
