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Chicago v. Noem

No. 1:25-cv-12765 District · Active
Court
N.D. Ill.
ilnd
Judge
Manish S. Shah 44
Filed
Oct 20, 2025
Judge (CL)
Manish S. Shah 44
Filed (CL)
Oct 20, 2025
CL Status
active


The Law · How the Case Works

Overview

Overview

A coalition of cities sued the Trump administration over the conditions being put on emergency preparedness funding which requires cities to enforce federal civil immigration law.

The Issue

Issue

Whether the federal government may condition emergency preparedness grants on cities' enforcement of federal civil immigration law, and whether such conditions violate the Spending Clause, Tenth Amendment, or anti-commandeering principles.

The Rules

Rule

Congress may attach conditions to federal grants only if the conditions are clearly stated, related to the federal program's purpose, and not so coercive as to pass the point of persuasion and become compulsion (South Dakota v. Dole, 483 U.S. 203 (1987)). States retain sovereign authority not delegated to the federal government, and the federal government cannot commandeer state resources to enforce federal law.

The Application

Analysis

Here, conditioning emergency preparedness funding on local immigration enforcement may fail the Dole test because the condition appears unrelated to emergency preparedness purposes, commandeers municipal resources for federal immigration enforcement, and threatens withdrawal of essential disaster-response funds to coerce compliance.

The Conclusion

Conclusion

The case remains active before Judge Manish S. Shah in the Northern District of Illinois as the court determines whether the grant conditions exceed constitutional limits on federal spending power and infringe on state sovereignty.

Court -
FiledOct 20, 2025
Judge Manish S. Shah 44
CL Statusactive
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Federal Court TMR-33af9ece Federal Grant Conditioning Aug 28, 2026
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