How have federal courts ruled on Trump-era immigration-related grant conditions and sanctuary-city directives?
Executive summary
Federal courts have delivered a fractured record on Trump-era efforts to condition federal grants and press sanctuary jurisdictions to cooperate with immigration enforcement: multiple district and circuit courts have blocked or narrowed enforcement of executive orders as unconstitutional or coercive [1] [2], while other appellate panels have upheld the Justice Department’s authority to impose conditions on specific grant programs [3] [4] [5]. That split — grounded in competing readings of the Spending Clause, separation of powers, and federal supremacy in immigration — has produced case-by-case rulings rather than a single uniform rule [6] [2].
1. The legal fight: executive orders, grant conditions and sanctuary policies
The controversy began with Trump executive orders and agency directives aimed at identifying “sanctuary jurisdictions” and conditioning grants on cooperation with federal immigration authorities; those orders directed the attorney general and DHS to publish lists and withhold funds from non‑compliant localities [2] [7]. Plaintiffs — cities and states with “sanctuary” policies that limit local collaboration with federal immigration enforcement — argued the White House was attaching new, coercive conditions to Congressionally authorized spending and attempting to commandeer local governments into enforcing federal law [1] [2].
2. Doctrinal lines: Spending Clause, commandeering, and vagueness
Courts addressing the fights have focused on three legal doctrines. First, whether the executive could attach new conditions under the Spending Clause without Congress’ authorization; judges skeptical of the administration found the orders attempted to impose conditions beyond what Congress had authorized [2] [1]. Second, the anti‑commandeering principle — that the federal government cannot force states to enact or administer federal programs — was invoked by courts that saw the directives as coercive attempts to make local law enforcement execute federal immigration policy [1]. Third, several courts faulted the orders for vagueness and due‑process problems when the administration failed to define “sanctuary” uniformly [7] [1].
3. A fractured appellate map: cases for and against the administration
The federal judiciary produced directly conflicting appellate outcomes. In some circuits and cases, judges ruled for the government, finding authority to withhold or condition grants — notably a Second Circuit panel and certain 2020 rulings that said the Justice Department could refuse Byrne‑Program funds to jurisdictions that didn’t cooperate [3] [4] [5]. In contrast, the Ninth Circuit and multiple district courts repeatedly blocked enforcement of the executive orders as unlawful overreach, with Judge William Orrick and allied courts issuing injunctions against broad funding cuts and holding parts of the orders unconstitutional [2] [1] [8]. Legal scholars and the Constitution Center note the split and emphasize that panels have reasoned differently about federal immigration supremacy versus limits on coercion [6].
4. Recent developments and enforcement posture as of 2025
The litigation continued into the Biden and subsequent administrations’ terms, with renewed suits and preliminary injunctions in 2025 that again barred the Trump administration from withholding funds or coercing cities unless they aided civil immigration enforcement; plaintiffs like San Francisco, Santa Clara County and Portland secured orders emphasizing separation‑of‑powers and Spending Clause violations [1] [9] [10]. Simultaneously, the Department of Justice has produced new lists labeling jurisdictions as “sanctuary,” and has filed fresh lawsuits against localities including Los Angeles, New York City and Denver [7]. The net is an uncertain enforcement environment where litigation, not a single Supreme Court resolution, continues to dictate outcomes [7] [6].
5. What the rulings mean going forward
Practically, the rulings leave two takeaways: first, the federal government retains some leverage over specific grant programs and may succeed in narrowly tailored conditions (as some appellate panels held for Byrne‑style grants) [3] [5]; second, broad, across‑the‑board threats to cut diverse federal funding as a means to compel local immigration enforcement face serious constitutional obstacles in many courts that see coercion, vagueness, and separation‑of‑powers problems [1] [2]. The divided circuit rulings and renewed litigation over lists and suits ensure that, absent Supreme Court clarification, outcomes will continue to vary by jurisdiction and program [6] [7].