Updated at 4:33 PM ET, November 6, 2025
A federal district court judge in Rhode Island has permanently ordered the U.S. Department of Transportation to tie federal transportation grants to state cooperation with federal immigration enforcement or the rollback of diversity, equity and inclusion policies.
The Nov. 4 order repeals the requirement nationwide and ends a months-long legal challenge brought by 20 states. The directive touched almost every stream of federal capital assistance that state transportation agencies rely on.
The dispute centers on an April 24 directive from Transportation Secretary Sean Duffy instructing governors, state DOTs and transit agencies to certify compliance with federal immigration detention requests and eliminate “policies, programs or activities based on prohibited classifications” that the federal DOT applied to a number of DEI initiatives.
Agencies that refused to comply risked suspension or cancellation of federal awards.
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California, Rhode Island and 18 other states— all but one led by Democratic governors—filed a lawsuit May 13 in Rhode Island court, arguing that the directive exceeded the department’s authority and sought to impose conditions that Congress never authorized under the Jobs and Infrastructure Investments Act or any other transportation statute.
The 123-page complaint claims that federal law contains no provision that allows the DOT to condition funds from the Federal Highway Administration and the Federal Railroad Administration on cooperation with immigration enforcement.
No legal basis
In his ruling, Chief Justice John J. McConnell Jr. found that the DOT failed to identify the statutory authority for its immigration enforcement status and violated the clear and reasoned decision-making requirements of the Administrative Procedure Act.
Applying the Supreme Court’s Spending Clause framework under South Dakota v. Dole, McConnell concluded that the condition lacked the necessary “relationship,” writing that the DOT presented “no plausible connection” between immigration enforcement cooperation and the purposes Congress established for federal transportation programs.
The court reinforced the findings of a preliminary ruling on June 19, when several states filed statements saying compliance with the directive would require agencies to violate state civil rights or sanctuary statutes.
Those filings also described uncertainty for work funded by the infrastructure law that was already under contract and for upcoming grant cycles, prompting agencies to halt internal compliance reviews until the court clarified DOT’s authority.
Programs administered by the Federal Highway Administration, Federal Transit Administration, Federal Railroad Administration, National Highway Traffic Safety Administration and Pipeline and Hazardous Materials Safety Administration were identified in the complaint as being subject to the condition.
Because DOT indicated that the directive applied to all federal grants, major competitive programs such as RAISE, INFRA, MEGA, and FTA’s capital investment grants also faced potential exposure.
Together, this formula and competitive programs distribute tens of billions of dollars annually for highway, transit, and rail capital improvements. A post-decision legal analysis states that McConnell’s decision nullifies the condition of all DOT grant agreements nationwide. The file does not show any request for suspension or notice of appeal filed by the agency after Nov. 6.
National level relay
The ruling’s nationwide sweep comes as the U.S. Supreme Court has sharply limited the ability of lower courts to issue such broad injunctions.
In a June decision, the high court held that district courts “generally cannot prohibit the government from enforcing a law or executive action against non-parties to a lawsuit,” according to a legal analysis by the Sidley law firm.
Other legal experts have made similar observations. An alert from a Dorsey & Whitney client noted that the scope of a federal court’s injunction must be “tailored to what is ‘necessary to provide complete relief to each plaintiff with standing to sue.'”
Legal observers say that while no party has sought a stay or appealed the scope of the order, the breadth of relief in California et al. v. US DOT could be examined under the new court rule.
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State officials praised the clarity the ruling provides. Rhode Island Attorney General Peter F. Neronha said the decision reaffirms the requirement that transportation dollars be tied to statutory purposes.
“[USDOT] they blatantly exceeded their statutory authority, violated the APA and transgressed well-established constitutional limitations on the conditions of federal funding,” he said. “The ability of Rhode Islanders to travel on safe roads and bridges cannot depend on the political whims of one man.”
Neronha praised the restorative certainty of long-planned work that depends on multi-year federal awards.
California Attorney General Rob Bonta said the ruling confirms the arguments the coalition made when the lawsuit was filed. “Today, a court finally struck down the Trump Administration’s illegal efforts to withhold critical public safety funding from states that refuse to carry out its mass deportation agenda,” he said.
Massachusetts Attorney General Andrea Campbell said the ruling protects “billions of dollars” in planned transportation improvements. He said the decision prevents the administration from forcing states to implement enforcement strategies that “have no bearing on mobility or transportation safety.”
Infrastructure lawyers say the ruling also strengthens procedural expectations for federal agencies. Ayelet Hirschkorn, a partner at Kaplan Kirsch in New York, said the decision “amplifies the importance of following established rulemaking processes to ensure that transit agencies have sufficient time to comment on proposed changes that affect current and future projects.”
He said by email that the ruling provides additional assurance that agencies can move forward with infrastructure work without facing “the difficult choice of walking away from federal funds that are key to the projects’ success.”
Hirschkorn noted that by declaring the restriction void, the order affects all 50 states, a result that differs from asserting broad injunctive relief and may invite future scrutiny under the Supreme Court’s ruling in Trump v. HOME He said he is not aware of any decision by the administration on whether he will appeal.
USDOT has not issued a public statement in response to the ruling and did not respond to multiple inquiries from ENR and other outlets as of Nov. 6. The court said it will continue to consider the remaining issues in the case, but the basic conditions have been permanently barred.
