Overview

• U.S. District Judge William Smith granted summary judgment to 20 states and the District of Columbia and issued a permanent injunction against the challenged conditions on FEMA-related grants.
• He ruled the policy unconstitutional under the Spending Clause and arbitrary and capricious under the Administrative Procedure Act for lacking a reasoned explanation and disregarding state reliance interests.
• The government’s mootness argument failed after the court determined DHS never formally rescinded the policy despite later saying it would apply to fewer programs.
• Smith wrote that forcing states to certify compliance with vague immigration requirements or risk losing critical funds leaves no meaningful choice and threatens irreparable harm to disaster readiness.
• The decision preserves access to billions in emergency and preparedness funding for the plaintiff jurisdictions, which argued the conditions would divert scarce state resources to federal civil immigration enforcement.