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Woonasquatucket River Watershed Council v. USDA

No. 25-1428 Circuit · Decided
Court
1st Cir.
ca1
Argued
Feb 5, 2026
Decided
Aug 7, 2026
Filed
May 1, 2025
Filed (CL)
May 1, 2025
CL Status
terminated


The Law · How the Case Works

Overview

Overview

The government appealed Judge McElroy's order granting a preliminary injunction which requires the executive branch disburse congressionally appropriated funds.

The Issue

Issue

Whether the executive branch may freeze congressionally appropriated funds directed to the Woonasquatucket River Watershed Council, or whether such withholding violates the Appropriations Clause and statutory spending requirements.

The Rules

Rule

Appropriated funds must generally be obligated and spent according to congressional intent; preliminary injunctions against government action require showing irreparable harm and likely success on the merits; the Antideficiency Act generally prohibits withholding or deferring funds except as specifically authorized by law.

The Application

Analysis

The district court found the Watershed Council likely to succeed on its claim that the funding freeze violated its rights to congressionally appropriated funds and that it faced irreparable harm from withholding. The court therefore granted a preliminary injunction requiring disbursement, which the government now appeals.

The Conclusion

Conclusion

The appeal is active before the First Circuit. The appellate court must determine whether the district court properly found likelihood of success on the merits and irreparable harm sufficient to warrant enjoining the executive branch to disburse the funds.

Court -
FiledMay 1, 2025
CL Statusterminated
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Court -
FiledMay 1, 2025
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No Supreme Court data for this case.

Federal Court TMR-6ffcc085 Federal Funding Freeze <br> Appeal of 1:25-cv-00097 Aug 11, 2026
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