Skip to main content

2.0

EO 14159 § 17 directs DOJ and DHS to take civil and criminal enforcement actions against “sanctuary jurisdictions”

  1. Original Date Announced

    January 20, 2025

    Section 17 of Executive Order (EO) 14159, "Protecting the American People Against Invasion," directs DOJ and DHS to ensure "sanctuary jurisdictions" do not receive Federal funding. Section 17 also directs DOJ and DHS to "evaluate and undertake any other lawful actions, criminal or civil, that they deem warranted based on any such jurisdiction’s practices that interfere with the enforcement of Federal law."

    Trump 2.0 [ID #1391]

    2025.01.20 EO 14159 - Protecting the American People Against Invasion
  2. Effective Date

    January 20, 2025
  3. Subsequent Trump and Court Action

    January 25, 2025

    2025.01.26 Complaint - Organized Communities Against Deportations v. Trump

    Just Futures Law and co-counsel filed a lawsuit on behalf of four grassroots organizations in Chicago challenging the administration’s planned immigration raids targeting Chicago as a "sanctuary city." Organized Communities Against Deportation v. Trump, No. 1:25-cv-00868 (N.D. Ill.). On January 26, 2025, the plaintiffs filed an amended complaint, which is the version included here.

    **Link to case here. Our litigation entries generally report only the initial complaint and any major substantive filings or decisions. For additional information, CourtListener provides access to PACER and all available pleadings. Other sites that track litigation in more detail or organize cases by topic include Civil Rights Clearinghouse, Justice Action Center, National Immigration Litigation Alliance, and Just Security**

    View Document
  4. Subsequent Trump and Court Action

    February 6, 2025

    2025.02.06 Complaint - United States v. State of Illinois

    The United States filed a lawsuit against the State of Illinois and others, including the city and mayor of Chicago, arguing that their sanctuary laws/policies obstruct and unlawfully impede the enforcement of federal immigration laws. United States v. Illinois, No. 1-25-cv-01285 (N.D. Ill.).

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

    View Document
  5. Subsequent Trump and Court Action

    February 7, 2025

    2025.02.07 Complaint - San Francisco v. Trump

    The City and County of San Francisco, Santa Clara County, Portland, King County, and New Haven sued President Trump, alleging that the threats to withhold federal funding from so-called sanctuary jurisdictions in Section 17 of EO 14159 and a related February 5, 2025 DOJ memo are unconstitutional and violate federal law. City and County of San Francisco v. Trump, No. 3:25-cv-01350 (N.D. Cal.).

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

    View Document
  6. Subsequent Trump and Court Action

    February 10, 2025

    Eric Adams releases updated ICE guidance after backlash

    In the context of direct pressure from Border Czar Tom Homan, NYC Mayor Eric Adams' administration distributed a memo to migrant shelter operators on February 4, 2025, instructing them to allow ICE in without a warrant if at any point workers feel reasonably threatened "or fear for your safety or the safety of others around you." Previous city guidance was that nonprofit shelter operators should not allow ICE agents entry without a warrant signed by a judge "except in exigent circumstances." The memo says that it took effect on January 13. See https://hellgatenyc.com/new-memo-ice-adams/.

    On February 10, 2025, Mayor Adams released additional guidance clarifying the January 13 memo. The memo was criticized, especially by the City Council which had threatened legal action. The administration presented a flow chart for action that omitted any reference to "fear." Instead, the presentations reportedly suggested that "[w]hile employees can verbally deny access to federal agents without a judicial warrant, they should not interfere with any actions of law enforcement personnel should officers decide to come in anyway."

    For additional Adams actions, see https://immpolicytracking.org/policies/eo-securing-our-borders-2f-promotes-federal-state-partnerships-to-enforce-federal-immigration-priorities/

    View Document
  7. Subsequent Trump and Court Action

    February 12, 2025

    2025.02.12 Complaint - United States v. State of New York

    The DOJ filed a suit against New York State as part of its crackdown on sanctuary jurisdictions. The lawsuit challenges the legality of New York's "Green Light Law," which, according to the complaint, "bars the sharing of New York State Department of Motor Vehicles (“DMV”) records or information . . . with federal immigration agencies." United States v. State of New York, No. 1:25-cv-00205 (N.D.N.Y.).

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

    View Document
  8. Subsequent Trump and Court Action

    February 19, 2025

    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.

    Illinois v. FEMA, No. 1:25-cv-00206 (D.R.I.).

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

    View Document
  9. Subsequent Trump and Court Action

    February 23, 2025

    2025.02.23 Complaint - Chelsea v. Trump

    Lawyers for Civil Rights filed suit on behalf of Chelsea and Somerville, MA, claiming that federal efforts to withhold funding would "violate the U.S. Constitution" and inhibit "efforts to enhance the safety of their own communities through well-considered law enforcement efforts and policy judgments." The lawsuit asks for Section 17 of Executive Order 14159, as well as several follow-on DOJ orders, to be declared unconstitutional, and to enjoin the Administration from proceeding "in furtherance of any withholding or conditioning of federal funds based on the Executive Order." City of Chelsea v. Trump, No. 1:25-cv-10442 (D. Mass.)

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

    View Document
  10. Subsequent Trump and Court Action

    February 26, 2025

    2025.02.26 Voluntary Dismissal - Organized Communities Against Deportations v. Trump

    Organized Communities Against Deportations and the other plaintiffs moved to voluntarily dismiss their lawsuit against the Trump administration. The plaintiffs point to ongoing immigration raids in the Chicago area, as well as the federal government's suit against Illinois, Chicago, and Cook County over sanctuary policies, as their reasons for seeking dismissal. Organized Communities Against Deportations v. Trump, No. 1:25-cv-00868 (N.D. Ill.).

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

    View Document
  11. Subsequent Trump and Court Action

    March 6, 2025

    2025.03.06 DOJ - U.S. Attorneys' Offices Staffing Priorities

    Deputy Attorney General Todd Blanche issues a memorandum on “U.S. Attorneys' Offices Staffing Priorities,” setting forth guidance ensure U.S. Attorneys’ Offices are appropriately staffed to address the administration’s immigration and crime priorities. The memo identifies Border Districts which are authorized to hire AUSAs despite the federal hiring freeze, including all Districts in Arizona, New Mexico, Texas, and Florida as well as the Southern District of California, Western and Northern Districts of New York, and the District of Vermont. The memo states this policy is critical to the implementation of EO 14159, specifically with regard to addressing “unlawful impediments to President Trump's immigration policy” by “state and local law enforcement, as well as misguided advocacy groups operating against the public interest.”

    View Document
  12. Subsequent Trump and Court Action

    April 11, 2025

    2025.04.11 Reported: New Jersey AUSA investigates Governor and AG over noncooperation policy - New York Times

    ​The New York Times reports that Alina Habba, interim U.S. Attorney for New Jersey, is investigating New Jersey Governor Phil Murphy and Attorney General Matt Platkin over their statewide Immigrant Trust Directive, which took effect in 2019 and limits the types of voluntary assistance the police, prosecutors, and correction officers may provide federal immigration authorities. Habba warned during an interview that anyone who "gets 'in the way'" of federal deportation efforts could face charges of obstruction and concealment.

    View Document
  13. Subsequent Trump and Court Action

    April 24, 2025

    2025.04.24 Complaint - United States v. City of Rochester

    The United States filed a lawsuit against the City of Rochester and others, including the city council and mayor, arguing that their sanctuary laws/policies, General Order 502 and Training Bulletin No. P-75-1, obstruct and unlawfully impede the enforcement of federal immigration laws. United States v. City of Rochester, No. 6:25-cv-06226 (W.D.N.Y).

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

    View Document
  14. Subsequent Trump and Court Action

    April 24, 2025

    2025.04.24 Preliminary Injunction - San Francisco v. Trump

    District Judge William Orrick issued a preliminary injunction, enjoining the federal government from "taking any action to withhold, freeze, or condition federal funds from the Cities and Counties based on (1) the first sentence of Section 17 of Executive Order 14159; (2) Section 2(a)(ii) of Executive Order 14218; or (3) the Preamble and Section I of the [DOJ Sanctuary Jurisdictions Directives]" on the basis of plaintiffs' policies that limit "(i) the honoring of civil immigration detainer requests; (ii) cooperation with administrative warrants for purposes of immigration enforcement; (iii) sharing of information with federal immigration authorities other than immigration or citizenship status; (iv) the use of local law enforcement to arrest or detain individuals solely for civil immigration violations; or (v) the use of local resources to assist with civil immigration enforcement activities." City and County of San Francisco v. Trump, No. 25-cv-01350 (N.D. Cal. 2025).

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

    View Document
  15. Subsequent Trump and Court Action

    May 2, 2025

    2025.05.02 Complaint - United States v. Colorado

    The United States filed suit against the State of Colorado, the City and County of Denver, and various officials, challenging Colorado’s “Sanctuary Laws” as unconstitutional. The litigation references Colorado laws prohibiting information sharing and limiting cooperation between state and local law enforcement and federal immigration authorities. The suit alleges that the laws violate the Supremacy Clause by obstructing federal immigration enforcement, by unlawfully discriminating against federal officials, and by directly regulating federal government activities. The complaint seeks declaratory and injunctive relief to block enforcement of the challenged laws. United States v. Colorado, No. 1:25-cv-01391 (D. Colo.).

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

    View Document
  16. Subsequent Trump and Court Action

    May 9, 2025

    2025.05.09 Order Clarifying Preliminary Injunction - San Francisco v. Trump

    District Judge William Orrick issued an order clarifying how the April 24, 2025 preliminary injunction related to EO 14287. 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**

    View Document
  17. Subsequent Trump and Court Action

    May 13, 2025

    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**

    View Document
  18. Subsequent Trump and Court Action

    May 22, 2025

    2025.05.22 Complaint - United States v. City of Newark

    The United States filed a lawsuit against the cities of Newark, Jersey City, Paterson, and Hoboken in New Jersey, as well as their elected officials, arguing that their sanctuary policies obstruct and unlawfully impede the enforcement of federal immigration laws. United States v. City of Newark, No. 2:25-cv-05081 (D.N.J.).

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

    View Document
  19. Subsequent Trump and Court Action

    June 12, 2025

    2025.06.12 Complaint - United States v. State of New York

    The DOJ filed suit against the state of New York and its elected officials, challenging New York's Protect Our Courts Act and two state executive orders under the Supremacy Clause. The Protect Our Courts Act makes it a crime to conduct civil immigration arrests of noncitizens at or on their way to or from a courthouse without a warrant. The challenged executive orders further prohibit civil immigration arrests of individuals within all state facilities and prohibit certain information sharing between state employees and federal officers. The suit alleges that the laws “pose intolerable obstacles to federal immigration enforcement and directly regulate and discriminate against the Federal Government." United States v. State of New York, No. 1:25-cv-00744 (N.D.N.Y.).

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

    View Document
  20. Subsequent Trump and Court Action

    June 30, 2025

    2025.06.30 Complaint - United States v. City of Los Angeles

    The DOJ filed suit against the City of Los Angeles over a 2024 city ordinance titled “Prohibition of the Use of City Resources for Federal Immigration Enforcement.” The ordinance prevents city personnel and property from being used to assist federal immigration agents in investigations, arrests, or detentions related to immigration enforcement. The suit alleges that the ordinance unlawfully regulates and discriminates against the federal government in violation of the Supremacy Clause, and is preempted by federal immigration law. United States v. City of Los Angeles, No. 2:25-cv-05917 (C.D. Cal.).

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

    View Document
  21. Subsequent Trump and Court Action

    July 25, 2025

    2025.07.25 Opinion Granting Motion to Dismiss - United States v. State of Illinois

    The District Court for the Northern District of Illinois granted the state and local Defendants' motion to dismiss for lack of jurisdiction and failure to state a claim. First, the Court held that the United States lacked Article III standing to sue individually named defendants. With regard to legal claims against Illinois, Cook County, and Chicago, the Court rejected the United States' expansive reading of 8 U.S.C. § 1373 for express preemption purposes regarding limitations on the sharing of information regarding contact information, custody status, and release date. The Court further held that while Chicago's Welcoming City Ordinance prohibiting sharing of "citizenship or immigration status" of a person would be expressly preempted by the federal statute's plain language, "§§ 1373 and 1644 are not valid preemptive provisions, as they regulate States and local governments, but not private actors."

    The Court also held that the sanctuary law does not frustrate any purpose underlying the Immigration and Nationality Act (INA) and is thus not conflict preempted. The Court concluded that even if the various sanctuary provisions were conflict preempted, the "Defendants’ decision to not participate in enforcing civil immigration law" is "a decision protected by the Tenth Amendment and not preempted by the INA." United States v. Illinois, No. 1-25-cv-01285 (N.D. Ill.).

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

    View Document
  22. Subsequent Trump and Court Action

    August 7, 2025

    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, filed a second amended complaint. 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**

    View Document
  23. Subsequent Trump and Court Action

    August 22, 2025

    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**

    View Document
  24. Subsequent Trump and Court Action

    September 4, 2025

    2025.09.04 Complaint - United States v. Boston

    The Department of Justice filed a lawsuit against the City of Boston alleging that the Boston Trust Act, which limits cooperation between local law enforcement and federal immigration authorities, violates the Supremacy Clause of the U.S. Constitution. The complaint asks the court to declare that the Boston Trust Act is unlawful and to enter preliminary and permanent injunctions against the enforcement of the law. United States v. City of Boston, No. 1:25-cv-12456 (D. Mass.).

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

    View Document
  25. Subsequent Trump and Court Action

    September 20, 2025

    2025.09.20 Reported: Trump administration threatens lawsuits, funding cuts if Democratic states don't hold migrants for ICE - CBS News

    CBS News reports that on September 10, 2025, Acting ICE Director Todd Lyons sent letters to the attorneys general of California, Illinois, and New York, ordering them to comply with immigration detainers. Response letters from California and Illinois stated that ICE detainers are “requests" with which state and local authorities cannot be forced to comply. On September 18, 2025, Lyons sent follow-up letters outlining ICE's plan for DOJ to sue the states and block future federal funding over what he described as obstruction of immigration enforcement.

    View Document
  26. Subsequent Trump and Court Action

    September 24, 2025

    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**

    View Document
  27. Subsequent Trump and Court Action

    September 29, 2025

    2025.9.29 Complaint - United States of America v. State of Minnesota

    DOJ filed a lawsuit against the state of Minnesota and other entities, including the cities of Minneapolis and St. Paul, and Hennepin County, arguing that their sanctuary laws and policies, including Article I, section 10 of the Minnesota Constitution—"to the extent that it prohibits state law enforcement agencies from detaining aliens pursuant to immigration detainers or performing immigration enforcement functions pursuant to [287(g)] agreements"—obstruct and unlawfully impede the enforcement of federal immigration laws in violation of the Constitution's Supremacy Clause. United States v. Minnesota, No. 0:25-cv-03798 (D. Minn.).

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

    View Document
  28. Subsequent Trump and Court Action

    October 14, 2025

    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**

    View Document
  29. Subsequent Trump and Court Action

    November 17, 2025

    2025.11.17 Order Granting MTD - United States v. State of New York

    District Judge Mae D'Agostino granted New York's motion to dismiss. The court held that New York's Protect Our Courts Act and executive orders, which limit certain federal immigration enforcement activities, are not preempted by federal law. It also found that the provisions do not violate intergovernmental immunity principles, rejecting the United States' argument that the provisions unlawfully regulate federal officials and discriminate against federal immigration authorities. The court explained that invalidating the laws upon intergovernmental immunity principles would be inconsistent with the Tenth Amendment and anti-commandering principles and notes that "commandeering is the entire purpose of this lawsuit." United States v. State of New York, No. 1:25-cv-00744 (N.D.N.Y.).

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

    View Document

Current Status

None

Original Trump Policy Status

Trump Administration Action: Presidential Orders
Subject Matter: Sanctuary Restrictions
Agencies Affected: AG DOJ DHS

Commentary

  • 2025.01.27 U.S. House Committee on Oversight and Government Reform Chairman Launches Investigation into Sanctuary Cities

    House Oversight and Government Reform Committee Chairman James Comer announced an investigation into "the policies of sanctuary jurisdictions and their impact on public safety and federal immigration enforcement." Chairman Comer called on the mayors of Boston, Chicago, Denver, and NYC to testify at a committee hearing on February 11, 2025.

    Go to article
  • 2025.04.18 ACLU - Know Your Rights: ICE Administrative Subpoenas

    The ACLU published a know-your-rights explainer about ICE administrative subpoenas. This KYR is aimed at officials in sanctuary jurisdictions, and at institutions such as hospitals, that wish to protect themselves against ICE investigations.

    Go to article

Documents

Trump-Era Policy Documents

To provide information, corrections, or feedback, please email IPTP.feedback@gmail.com