Woonasquatucket River Watershed Council v. USDA
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
On August 7, 2026, the First Circuit affirmed the district court’s grant of injunctive relief with one exception. Chief Judge Barron, joined by Judges Lipez and Rikelman, vacated paragraph 3 of Judge McElroy’s April 15, 2025 order but otherwise affirmed the opinion and order, leaving the executive branch bound to disburse the congressionally appropriated funds. The government’s appeal failed on the core relief, and the appeal is terminated.
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