Another Federal Court Blocks the Trump Administration's Destruction of IMLS

A federal judge in Rhode Island on May 6 granted a motion blocking the Trump administration's attempt to dismantle the Institute of Museum and Library Services and several other federal agencies.

The highly anticipated decision comes in a lawsuit filed by 21 states on April 4, and just days after federal judge Richard J. Leon in Washington D.C. issued a May 1 temporary restraining order (TRO) blocking the further dismantling of the IMLS in a parallel case brought by the American Library Association. The decision also comes after the administration on May 2 proposed the elimination of the IMLS in its FY 2026 budget blueprint.

In a 49-page opinion granting the states' motion for a preliminary injunction, judge John G. McConnell held that Trump’s March 14 executive order “attempts to dismantle congressionally sanctioned agencies and ignores congressionally appropriated funds,” in violation of the Administrative Procedures Act (APA) and “the fundamental constitutional role of each of the branches of our federal government.” McConnell found that Trump’s order (and the subsequent actions taken by administration officials to implement it) “ignores the unshakable principles that Congress makes the law and appropriates funds, and the Executive implements the law Congress enacted and spends the funds Congress appropriated.”

In granting the motion, judge ordered the parties to immediately confer on a draft order for relief. Furthermore, citing the potential for further irreparable harm, McConnell denied the administration’s request for a stay pending appeal.

The ruling is yet another sharp rebuke for the Trump administration—and the second delivered by McConnell, an Obama appointee, who has already issued one injunction blocking the Trump Administration’s attempt to freeze as much as $3 trillion in federal funding for programs the administration does not support.

In his ruling, McConnell swiftly dispatched with arguments made by the administration in its April 14 opposition brief, which hinged entirely on issues of law. In their filing, DOJ attorneys had argued that the court lacked jurisdiction to hear the states’ case because any dispute over canceled grants belonged in the Federal Court of Claims, while any dispute over job reductions should be heard before “administrative bodies” established by the Congress via Civil Service Reform Act. Furthermore, DOJ lawyers asserted that the case was not ripe because the actions taken by administration officials to dismantle the agencies were not “final acts” as required by the APA.

But McConnell said the "compelling" evidence of harm stemming from the dismantling of IMLS and other agencies—including staff reductions, canceled grants, and the impact on the communities deprived of the services the agencies support—made the case “sufficiently ripe.” And because the States’ challenges are based on “alleged statutory and constitutional violations," the states' claims are not subject to the “exclusive jurisdiction" of the Federal Court of Claims.  

Furthermore, McConnell found that the mass terminations of grants and staff at IMLS and other agencies were not done reasonably, meeting the APA’s threshold precluding “arbitrary and capricious” acts.

“What the unrefuted evidence reveals is that, to comply with the [Executive Order] IMLS, MBDA [Minority Business and Development Agency], and FMCS [Federal Mediation And Conciliation Service], each adopted a policy to eliminate all non-statutorily required activities and functions and reduce their statutory functions and personnel to the bare minimum,” McConnell wrote. “But the Defendants have not shown that any analysis was conducted to determine which ‘components and functions’ of IMLS, MBDA, and FMCS are statutorily required, and which are not.”

Rather, McConnell found, the “justifications for eliminating programs, terminating grants, and implementing large-scale employee [layoffs] have been couched in mere conclusory statements—most of which merely defer to the [executive order]," lacking any “rational connections” or explanations" about why the targeted programs or grants fell within the ambit of ‘non-statutory’ functions or components.”

And in something of a civics lecture, McConnell found that the administration’s refusal to spend the funds allocated by congress clearly “usurped Congress’s power of the purse and ‘legislative supremacy’" in violation of the Constitution’s separation of powers.

“By making laws, Congress has expressly restricted the Executive Branch from taking control of its appropriation powers," the decision states. “The President does not have unilateral authority to refuse to spend funds. Instead, the President must propose the rescission of funds, and Congress then may decide whether to approve a rescission bill… But that process was not facilitated here. Rather, IMLS, MBDA, and FMCS took actions that essentially directed the rescission of funds to fulfill the President’s policy—with congressional authorization glaringly absent.”

At press time, it is not clear how quickly the parties will deliver a proposed order for relief and what relief the court might order.

Update May 9, 2025:

In a filing on May 9, the parties submitted a proposed injunction in the case.

Among its provisions, the injunction, if adopted by the court, would bar the Trump Administration from “implementing, giving effect to, or keeping in force any policies, memoranda, directives, or actions issued prior to the date of this order that were designed or intended, in whole or in part, to implement, give effect to, comply with, or carry out the directives contained in [Trump’s March 14 executive order]” as it pertains to the Institute of Museum and Library Services (IMLS), the Minority Business Development Agency (MBDA), or the Federal Mediation and Conciliation Service (FMCS)."

Furthermore the order would mandate the administration to “reverse any policies, memoranda, directives, or actions issued prior to the date of this order that were designed or intended, in whole or in part, to implement, give effect to, comply with, or carry out the directives contained in [the March 14 executive order]. And it would “bar any further action during the pendency of this case to “eliminate[]” “the non-statutory components and functions” of IMLS, MBDA, or FMCS, or to “reduce the performance of their statutory functions and associated personnel to the minimum presence and function required by law.”

The court has also set a hearing for May 13.