Illinois Attorney General Kwame Raoul and a coalition of 20 attorneys general secured a significant legal victory Thursday when a federal judge blocked the Trump administration from withholding billions in transportation funding from states that refuse to cooperate with federal immigration enforcement. The preliminary injunction, issued just one day before a critical grant application deadline, prevents what the states called an unconstitutional attempt to weaponize federal infrastructure dollars.
Chief U.S. District Judge John McConnell Jr. of Rhode Island granted the states' request for emergency relief, finding that Reuters reported would cause "large-scale irreparable harm" without court intervention. The ruling came ahead of a June 20 deadline that would have required states to agree to new immigration enforcement conditions to receive federal grants for roads, bridges, airports, and rail safety projects.
The Duffy Directive Under Legal Fire
The legal challenge centers on what attorneys general dubbed the "Duffy Directive," issued in April by Transportation Secretary Sean Duffy. According to NPR, the directive required states to "cooperate with Federal officials in the enforcement of Federal immigration law" as a condition for receiving congressionally appropriated transportation funds. The policy would have affected more than $100 billion in annual federal transportation grants that states rely on for critical infrastructure projects.
"States rely on billions of dollars appropriated by Congress to keep our residents safe as they travel our roads, railways and the skies," Raoul stated in response to Thursday's ruling, as reported by the Illinois Attorney General's office. "This critical funding has nothing to do with immigration, and the administration's attempt to hold it hostage unless states agree to do the federal government's job of civil immigration enforcement is unconstitutional and outrageous."
Constitutional Separation of Powers at Stake
Judge McConnell's ruling found that the Department of Transportation lacked authority to impose immigration enforcement conditions on transportation funding. Newsweek reported the judge's pointed criticism: "The Government does not cite to any plausible connection between cooperating with ICE enforcement and the congressionally approved purposes of the Department of Transportation." The decision emphasized that such conditions would allow the executive branch to place any restrictions it chose on congressionally appropriated funds, undermining the constitutional balance of power.
For Illinois specifically, the stakes were substantial. According to NPR Illinois, the state received more than $2 billion in highway funding, $122 million for disaster recovery, $60 million for counterterrorism efforts, and $24 million to protect nonprofits from extremist attacks last year alone. The administration's conditions would have put all of this funding at risk.
Broader Pattern of Federal Funding Disputes
Thursday's ruling represents the latest in a series of legal victories for states challenging the Trump administration's attempts to tie federal funding to immigration compliance. This case follows similar disputes over FEMA funding and education grants, with Judge McConnell previously blocking multiple administration funding freezes. Rhode Island Current reported that McConnell has repeatedly found the administration's funding restrictions "likely unconstitutional."
The transportation funding case emerged from a broader legal strategy targeting so-called sanctuary jurisdictions. Reuters previously reported that another federal judge blocked similar funding restrictions affecting 16 sanctuary cities and counties in April. These jurisdictions argue that requiring local law enforcement to assist with federal immigration operations undermines community trust and diverts resources from local crime prevention.
Strong Opposition from State Leaders
The coalition challenging the transportation directive included attorneys general from California, New York, Massachusetts, and 17 other states. New York Attorney General Letitia James celebrated the victory on social media, writing on X: "We just won a court order blocking @USDOT's illegal attempt to tie transportation funding to immigration enforcement. We will keep fighting to protect our immigrant communities and ensure our roads, airports, and transit systems get the support they need," according to Newsweek.
Transportation Secretary Duffy responded defiantly to the ruling, telling Newsweek: "I directed states who want federal DOT money to comply with federal immigration laws. But, no surprise, an Obama-appointed judge has ruled that states can openly defy our federal immigration laws. This is judicial activism pure & simple and I will continue to fight in the courts."
Legal Implications and Next Steps
Legal experts view the ruling as significant for federal-state relations and the limits of executive power. The decision reinforces precedents that Congress, not federal agencies, determines the conditions for appropriated funds. Democracy Docket noted that such rulings protect the constitutional separation of powers by preventing agencies from imposing conditions that Congress never authorized.
The Trump administration is expected to appeal Thursday's ruling to the First Circuit Court of Appeals. However, appeals courts have generally upheld lower court decisions blocking similar funding restrictions. The preliminary injunction remains in effect while litigation continues, ensuring states can access transportation funding without agreeing to immigration enforcement conditions.
Attorney General Raoul's office has been at the forefront of challenging various Trump administration policies, with involvement in more than 20 lawsuits since January. Chicago Sun-Times reported that Raoul recently told reporters "We are winning" when asked about the success rate of these legal challenges.
