Illinois v. Trump (2025 Natl Guard, Appeal)

The Seventh Circuit applies the Spending Clause framework to conclude that the Trump administration's conditioning of federal grants on immigration enforcement cooperation lacks the statutory authorization required by established precedent. The orders attempt to attach new compliance obligations to funds Congress appropriated for unrelated programs without clear legislative authority to do so, and City of Chicago v. Barr, decided within the same circuit just five years earlier, directly forecloses this executive approach. Additionally, by pressuring local officials to cooperate with ICE enforcement or lose federal funding, the orders implicate the anti-commandeering doctrine's prohibition on federal coercion of state and local government officials. The preliminary injunction reflects the court's preliminary finding that the plaintiffs are likely to succeed on the merits that these conditions exceed presidential authority under the Spending Clause.