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State of New York v. Noem

No. 1:25-cv-08106 District · Decided Decided
Court
Federal Court
nysd
Judge
Lewis A. Kaplan 42
Decided
Oct 16, 2025
Filed
Sep 30, 2025
Judge (CL)
Lewis A. Kaplan 42
Filed (CL)
Sep 30, 2025
CL Status
terminated

Case Overview

New York sued the Department of Homeland Security over the cancellation of counterterrorism funding, allegedly in an attempt to punish the state for not cooperating with federal law enforcement.


The Application

History

New York alleged that DHS cancelled counterterrorism funding as punishment for the state's refusal to cooperate with federal law enforcement priorities. If the cancellation was retaliatory rather than based on neutral, pre-announced criteria, it would constitute an impermissible condition on federal funds conditioning continued receipt on state compliance with federal enforcement priorities.

The Conclusion

The court decided the case as of September 30, 2025, resolving whether the funding cancellation constituted unconstitutional retaliation or fell within the government's lawful spending authority.

Outcome History (3)

  1. Oct 1, 2025 District
    TRO granted Partial relief

    Temporary Restraining Order granted, enjoining defendants from certain actions regarding federal funds.

  2. Oct 15, 2025 District
    Other Unresolved

    Order consolidating preliminary injunction motion with trial on the merits and extending temporary restraining order.

  3. Oct 16, 2025 District
    Preliminary injunction granted Full relief Final

    Final Judgment and Permanent Injunction granted, establishing the amount of federal funds for TSGP Grant.

Federal Court TMR-d64c28be Federal Grant Conditioning May 18, 2026

Case Analysis

Issue

Whether the federal government may cancel federal counterterrorism funding to a state in retaliation for the state's refusal to cooperate with federal law enforcement, or whether such action violates the unconstitutional conditions doctrine and retaliation principles.

Rule

Under the unconstitutional conditions doctrine and Spending Clause framework, the federal government cannot condition the receipt of federal funds on the surrender of constitutional rights, and cannot retaliate against states for exercising constitutional or statutory prerogatives. Conditions on federal spending must be clearly stated and cannot be coercive (South Dakota v. Dole, 483 U.S. 203).

Analysis

New York alleged that DHS cancelled counterterrorism funding as punishment for the state's refusal to cooperate with federal law enforcement priorities. If the cancellation was retaliatory rather than based on neutral, pre-announced criteria, it would constitute an impermissible condition on federal funds conditioning continued receipt on state compliance with federal enforcement priorities.

Conclusion

The court decided the case as of September 30, 2025, resolving whether the funding cancellation constituted unconstitutional retaliation or fell within the government's lawful spending authority.

Overview

New York sued the Department of Homeland Security over the cancellation of counterterrorism funding, allegedly in an attempt to punish the state for not cooperating with federal law enforcement.

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