Original Date Announced

Sec. 2 of EO 14287, "Protecting American Communities From Criminal Aliens," requires the Attorney General (AG) and the Secretary of Homeland Security (DHS) publish a running list of sanctuary States and local jurisdictions. It also requires the AG and DHS notify those sanctuary jurisdictions "regarding [their] defiance of Federal immigration law enforcement and any potential violations of Federal criminal law."

Sec. 3 describes potential consequences for such jurisdictions if they refuse to change their policies. Sec. 3(a) states "the head of each executive department or agency . . . shall identify appropriate Federal funds to sanctuary jurisdictions . . . for suspension or termination. . . ." Sec. 3(b) notes that if any jurisdiction remains a sanctuary jurisdiction after notification, the AG and DHS will "pursue all necessary legal remedies and enforcement measures to end these violations . . . ."

Sec. 1 of the EO says certain State and local actions could violate criminal laws regarding obstruction of justice (18 USC 1501), unlawful harboring or hiring illegal aliens (8 USC 1324), conspiracy against the United States (18 USC 371), and conspiracy to impede Federal law enforcement (18 USC 372), and assisting noncitizens in violating immigration law could violate the Racketeer Influenced and Corrupt Organizations Act (RICO) (18 USC 1961).

Trump 2.0 [ID #1717]

Subsequent Trump and Court Action

2025.05.09 Order Clarifying Preliminary Injunction - San Francisco v. Trump

District Judge William Orrick issued an order clarifying how a preliminary injunction enjoining enforcement of EOs 14159 and 14218 in litigation detailed in related entries applies to EO 14287. The City and County of San Francisco had filed suit against the Trump administration in February 2025 to challenge EO 14159, EO 14218, and the DOJ's February 5, 2025 Sanctuary Jurisdictions Directive. Judge Orrick issued a preliminary injunction on April 24, 2025, enjoining the government from taking any action to withhold, freeze, or condition federal funds based on (1) the first sentence of Section 17 of EO 14159; (2) Section 2(a)(ii) of EO 14218; or (3) the Preamble and Section I of the DOJ Sanctuary Jurisdictions Directive on the basis of the City’s sanctuary policies.

In an order clarifying the April 24, 2025 preliminary injunction, the court held that "neither Executive Order 14,287 nor any other Government Action that postdates the Preliminary Injunction can be used as an end run around the Preliminary Injunction Order." It clarifies that the preliminary injunction applies to any EO or agency directive that "purports to attempt to cut off federal funding from States or localities that meet the Government’s definition of 'sanctuary' jurisdiction in the wholesale, overly broad and unconstitutional manner threatened by Section 17 of EO 14,159 and Section 2(a)(ii) of EO 14,218."

City and County of San Francisco v. Trump, No. 3:25-cv-01350 (N.D. Cal.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.05.13 Complaint - Illinois et al v. FEMA

Twenty states filed a complaint against the Federal Emergency Management Agency (FEMA) in the U.S. District Court for the District of Rhode Island challenging the administration's threat to withhold federal funding unless the states complied with federal immigration enforcement demands, as outlined in the executive order above. State of Illinois v. FEMA, No. 1:25-cv-00206 (D.R.I.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.05.13 Complaint - California et al v. Department of Transportation

Twenty states filed a complaint against the U.S. Department of Transportation in the U.S. District Court for the District of Rhode Island challenging the administration's threat to withhold federal funding unless the states complied with the federal immigration demands, as outlined in the executive order above. State of California v. U.S Department of Transportation, No. 1:25-cv-00208 (D.R.I.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.05.31 Sanctuary Jurisdictions Defying Federal Immigration Law

Pursuant to the requirement in EO 14287, DHS issued a press release and launched a website that it says will contain a regularly updated list of cities, counties, and states that it calls "sanctuary jurisdictions."

Subsequent Trump and Court Action

2025.06.01 Reported: DHS removes list of 'sanctuary' cities after sheriffs push back on non-compliant label - Reuters

Reuters reports that DHS removed its list of "sanctuary jurisdictions" from its website following criticism from the National Sheriffs' Association, which represents over 3,000 elected sheriffs nationwide. Association President Sheriff Kieran Donahue condemned DHS for releasing the list without consulting sheriffs, saying the move lacked transparency and accountability and violated "the core principles of trust, cooperation, and partnership with fellow law enforcement."

Subsequent Trump and Court Action

2025.06.17 US Statement of Interest - Huntington Beach v. California

The United States filed a Statement of Interest in City of Huntington Beach v. California, a challenge by the City of Huntington Beach to the California Values Act, which restricts local law enforcement agencies from cooperating with federal immigration authorities. The statement argues that California’s sanctuary policies are preempted by federal law and violate the Supremacy Clause of the Constitution. By obstructing federal immigration enforcement, it asserts, the state laws endanger public safety and impede the removal of criminal noncitizens.

District Judge Sunshine Sykes granted the State of California’s motion to dismiss on December 1, 2025. City of Huntington Beach v. California, No. 8:25-cv-00026 (C.D. Cal.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.02.19 Memorandum from DHS Secretary Noem Restricting Grant Funding for Sanctuary Jurisdictions - Illinois v. FEMA

DHS Secretary Noem sent a memorandum directing agencies to review all federal financial assistance awards to determine if DHS is funding "sanctuary jurisdictions" and, if so, to cease that funding. The memorandum defines the following as "sanctuary jurisdictions":

• Jurisdictions that fail to comply with the information sharing requirements of 8 U.S.C. §§ 1373 and 1644.
• Jurisdictions that encourage a noncitizen to enter or reside in the U.S., or that harbor or shield noncitizens from detection;
• Jurisdictions that fail to honor DHS requests for cooperation;
• Jurisdictions that fail to provide access to detainees; and
• Jurisdictions that leak the existence of an enforcement operation.

The memorandum was filed as part of litigation in Illinois v. FEMA, No. 1:25-cv-00206 (D.R.I.), but had been issued on February 19, 2025.

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.08.05 DOJ - Justice Department Publishes List of Sanctuary Jurisdictions

Pursuant to Executive Order 14287, DOJ published a list of states, cities, and counties that purportedly have "policies, laws, or regulations that impede enforcement of federal immigration laws." DOJ states that the list of so-called "sanctuary jurisdictions" is not exhaustive and will be updated as federal authorities gather information. The press release notes "[t]he federal government will assist any jurisdiction that desires to be taken off this list to identify and eliminate their sanctuary policies, so they no longer stand in opposition to federal immigration enforcement."

Subsequent Trump and Court Action

2025.08.07 Second Amended Complaint - City and County of San Francisco v. Trump

The City and County of San Francisco, along with multiple other local governments, sued to challenge EO 14287. The complaint alleges that through EO 14159, EO 14218, EO 14287, and the DOJ Sanctuary Jurisdictions Directive, "Defendants are unilaterally imposing new conditions on federal funding without authorization from Congress" and coercing states into cooperating with federal immigration law in violation of the Tenth Amendment, separation of powers principles, and the Spending Clause. The plaintiffs also allege that EO 14287 is void for vagueness, violates the plaintiffs' procedural due process rights, and is arbitrary and capricious, contrary to constitutional right, and in excess of statutory authority under the Administrative Procedure Act (APA). City and County of San Francisco v. Trump, No. 3:25-cv-01350 (N.D. Cal.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.08.13 Letter from Attorney General Pam Bondi to Governor Kathy Hochul

Attorney General Pam Bondi sent a letter to New York Governor Kathy Hochul informing her that New York is on the list of sanctuary jurisdictions compiled pursuant to EO 14287. The letter requested a response by August 19, 2025 that "confirms [the Governor's] commitment to complying with federal law and identifies the immediate initiatives [the Governor is] taking to eliminate laws, policies, and practices that impede federal immigration enforcement."

Subsequent Trump and Court Action

2025.08.22 Order Granting Second Preliminary Injunction - San Francisco v. Trump

District Judge William Orrick issued a preliminary injunction enjoining the federal government from “directly or indirectly taking any action to withhold, freeze, or condition federal funds” based on (1) the first sentence of Section 17 of EO 14159; (2) Section 2(a)(ii) of EO 14218; (3) the DOJ Sanctuary Jurisdictions Directive; or (4) “any other Executive Order or Government action that poses the same coercive threat to eliminate or suspend federal funding based on the Government’s assertion that a jurisdiction is a ‘sanctuary jurisdiction[.]’”

The order finds that the challenged executive orders and related agency directives violate the Spending Clause, separation of powers principles, Fifth and Tenth Amendments, and Administrative Procedure Act. The order also clarifies that the preliminary injunction reaches conditions imposed by the Department of Housing and Urban Development on Continuum of Care grants.

City and County of San Francisco v. Trump, No. 3:25-cv-01350 (N.D. Cal.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.09.24 Permanent Injunction - Illinois v. FEMA

The U.S. District Court for the District of Rhode Island issued a permanent injunction barring the federal government from enforcing conditions on the distribution of federal funding to states designated as sanctuary jurisdictions. The order found these conditions arbitrary and capricious in violation of the Administrative Procedure Act (APA) and unconstitutional in violation of the Spending Clause. State of Illinois v. FEMA, No. 1: 25-cv-00206 (D.R.I.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.09.26 Justice Department Announces Memorandum of Understanding with Nevada to Collaborate on Immigration Enforcement

DOJ released a Memorandum of Understanding with Nevada through which the two "agree to cooperate to the extent allowed by law to ensure federal law is followed in immigration enforcement and to develop further opportunities for Nevada's cooperations with federal law enforcement."

Nevada agrees to "utilize Federal Emergency Management Agency (FEMA) funds to assist in federal operations," "employ the National Guard to provide administrative support for federal law enforcement in immigration operations within the State of Nevada," and "take steps available in law to counter-balance any actions the Nevada Attorney General and Nevada Legislature may take to enact unlawful sanctuary policies."

Subsequent Trump and Court Action

2025.10.14 Enforcement Order - Illinois et al v. FEMA

The U.S. District Court for the District of Rhode Island found that despite its permanent injunction from September 24, 2025, the federal government inserted the contested conditions into plaintiff states’ award letters with statements that the conditions will become effective if the injunction is stayed, vacated, or extinguished. The court held that the conditional nature of the requirement “makes little difference;” because the conditions are unlawful, the plaintiff states must be permitted to accept the awards without regard to the contested conditions. It vacated the conditions and ordered that the award documents be amended to remove such conditions within seven days. Illinois v. FEMA, No. 1: 25-cv-00206 (D.R.I.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.10.24 Amended Complaint - Illinois v. Noem

12 states and the District of Columbia filed an amended complaint to challenge a new requirement imposed by DHS on September 30, 2025, that state-recipients of Emergency Management Performance Grant certify their own populations excluding deported individuals. The amended complaint states that “[r]eal-time population figures are simply impossible to provide, and they are made doubly impossible by the demand to incorporate information about deportations that DHS alone holds.” Plaintiffs also challenge FEMA’s decision to reduce their funding under the Homeland Security Grant Program; they allege that FEMA reduced only allocations of certain states it views as “sanctuary” jurisdictions, while increasing other states’ allocations.

Plaintiffs argue that the population-certification requirement and reallocation decision violate the Administrative Procedure Act (APA). The original complaint, challenging only the reallocation decision, was filed on September 29, 2025, and is described further here. Illinois v. Noem, No. 1:25-cv-00495 (D.R.I.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.10.31 DOJ - Removal of Baltimore County from Sanctuary Jurisdiction List following Memorandum of Understanding with ICE to Collaborate on Immigration Enforcement

The DOJ announced the removal of Baltimore County, Maryland as a designated sanctuary jurisdiction from its August 5, 2025, list after the County signed a Memorandum of Understanding with ICE to collaborate on immigration enforcement.

Subsequent Trump and Court Action

2026.02.11 Complaint - Illinois v. Vought

Illinois, California, Colorado, and Minnesota filed suit against the Trump administration to challenge an OMB directive that was issued in early February and commanded federal agencies to cut funding to plaintiff states. The complaint alleges that the OMB directive has been put into effect so far by HHS, which instructed the CDC to rescind more than $600 million of HHS funding from the plaintiff states, consistent with the executive order described above.

The states allege that the OMB directive is part of a "long-running pattern" of targeting sanctuary jurisdictions for funding terminations and other retaliation. The states argue that the agencies' actions exceed statutory authority and violate the Administrative Procedure Act (APA), the Tenth Amendment, the Spending Clause of the Constitution, and the principle of separation of powers. The states seek a preliminary injunction and ask the court to declare unlawful and vacate the OMB directive. Illinois v. Vought, No. 1:26-cv-01566 (N.D. Ill.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2026.03.12 Grant of Partial Preliminary Injunction - Illinois v. Vought

District Judge Manish Shah granted in part the plaintiff states' request for a preliminary injunction. The court found that the states are likely to succeed on their claim that OMB’s targeting of them for cuts violates the APA and the Constitution and exceeds statutory authority; that the states would suffer irreparable harm without injunctive relief; and that the states' "sovereign interests . . . outweigh the executive branch’s likely unlawful interest in using preauthorized funding to shape state-run governance." The court preliminarily enjoined the agencies from implementing guidance or directives to target the states for cessation of HHS or CDC funding after January 13, 2026. The court also denied the federal government's request that the states post bond in the amount of any interest that would accrue on the funds. Illinois v. Vought, No. 1:26-cv-01566 (N.D. Ill.).

**Link to case here. See litigation note above**