Fresno v. Noem

Overview

A coalition of cities in California sued the Trump administration over conditions placed on federal grants that require cities to follow certain executive branch policies.

Issue

Whether the Trump administration may condition receipt of federal grants on cities' compliance with specific executive branch policies, and whether such conditioning violates the constitutional rights of the municipalities.

Rule

Under the Spending Clause, Congress may condition grants on reasonable requirements related to the federal interest, but the conditions must be unambiguous and not induce states or localities to engage in unconstitutional conduct. See South Dakota v. Dole, 483 U.S. 203 (1987); Texas v. Biden, 40 F.4th 205 (5th Cir. 2022).

Analysis

The cities challenge conditions requiring municipal compliance with executive policies as exceeding constitutional limits on federal spending power and potentially infringing municipal sovereignty and constitutional rights. The court must determine whether the conditions are sufficiently related to the federal grants' purposes and whether they unconstitutionally coerce the cities' policy choices.

July 9, 2026 - Preliminary Injunction Granted

"What defendants seek to do likely violates the Constitution (separation of powers and Spending Clause) and the Administrative Procedures Act, 5 U.S.C. § 551 et seq. (“APA”). The result of their imposition of the Challenged Conditions would irreparably injure plaintiffs and their ability to provide critical services, as well as would threaten public safety. I GRANT plaintiffs’ motion to enjoin enforcement of the Challenged Conditions at DHS, DOJ, and DOI in grants for which plaintiffs have applied or intend to apply.

https://storage.courtlistener.com/recap/gov.uscourts.cand.464641/gov.uscourts.cand.464641.33.0.pdf

Conclusion

The case remains active as of the filing date, with the court evaluating whether the grant conditions survive constitutional scrutiny under spending power and rights-based challenges.