Illinois v. Trump (2025 Natl Guard, Appeal)
Case Overview
The government appealed Judge Perry's temporary restraining order which prevents the Trump administration from federalizing and deploying National Guard troops within Illinois.
BrynoDC Coverage 2 videos
The Facts
President Trump signed executive orders in January and February 2025 directing federal agencies to condition grants on jurisdictions' cooperation with immigration enforcement, including sharing information with ICE and honoring civil immigration detainer requests. Illinois, Chicago, and other sanctuary jurisdictions sued, arguing the orders amount to an unconstitutional attempt to commandeer local law enforcement and attach new conditions to congressionally appropriated funds without statutory authority. The district court entered preliminary relief; the government appealed.
The Application
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.
The Conclusion
**Active, preliminary injunction in place. The Seventh Circuit is the latest court to consider whether the Trump administration's immigration-enforcement grant conditions are lawful.** The case is part of a broader wave of sanctuary-city litigation testing the constitutional limits of executive spending conditions.
Case Analysis
Facts
President Trump signed executive orders in January and February 2025 directing federal agencies to condition grants on jurisdictions' cooperation with immigration enforcement, including sharing information with ICE and honoring civil immigration detainer requests. Illinois, Chicago, and other sanctuary jurisdictions sued, arguing the orders amount to an unconstitutional attempt to commandeer local law enforcement and attach new conditions to congressionally appropriated funds without statutory authority. The district court entered preliminary relief; the government appealed.
Issue
Whether the President may by executive order condition previously appropriated federal grants on sanctuary jurisdictions' compliance with federal immigration enforcement directives, without independent statutory authority to impose those conditions.
Rule
Spending Clause (U.S. Const. Art. I, § 8, cl. 1) requires that conditions on federal grants be unambiguous, related to the federal interest in the program, and authorized by Congress. Not imposed unilaterally by the executive. City of Chicago v. Barr (7th Cir. 2020) previously struck down similar conditions under the Sessions-era DOJ. The anti-commandeering doctrine (Printz v. United States, 1997) bars the federal government from conscripting state and local officials to enforce federal law.
Analysis
Trump's alleged coordination with co-conspirators to contact Georgia officials and pressure vote-count alterations constitutes potential racketeering and conspiracy under Georgia law; these campaign-related acts fall outside the scope of official presidential conduct shielded by immunity.
Conclusion
**Active. Preliminary injunction in place. The Seventh Circuit is the latest court to consider whether the Trump administration's immigration-enforcement grant conditions are lawful.** The case is part of a broader wave of sanctuary-city litigation testing the constitutional limits of executive spending conditions.
Notes
ACTIVE LITIGATION as of mid-2025. Verify current status before publication.
Overview
The case involves charges against Donald Trump for racketeering, solicitation of violation of oath by a public officer, and multiple conspiracies related to efforts to pressure Georgia officials to alter the 2020 vote count. As of November 17, 2025, the case was at a critical stage after the prior prosecutor was removed by the Court of Appeals due to an appearance of impropriety. On November 14, 2025, a new pro tem prosecutor, Peter Skandalakis, was appointed to carry the case forward, with presidential immunity considered unlikely because the acts were campaign-related rather than official duties.
Overview
The government appealed Judge Perry's temporary restraining order which prevents the Trump administration from federalizing and deploying National Guard troops within Illinois.
Flag an issue
This tracker is maintained by BrynoDC and is free because readers fund it. Support