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On April 15, 2025, a federal district judge issued a preliminary injunction requiring the Environmental Protection Agency and the Departments of the Interior, Energy, Housing and Urban Development, and Agriculture to unfreeze funds appropriated under the Infrastructure Investment and Jobs Act (IIJA) and Inflation Reduction Act (IRA). The order enjoins the Administration from implementing Memorandum M-25-11, a directive implementing Executive Order 14154 on “Unleashing American Energy.” The injunction applies to freezes issued on a non-individualized basis for awards already made, and it applies to all IRA and IIJA grants, not just those of the plaintiffs. The ruling also prevents the Office of Management and Budget and named officials from implementing Memorandum M-25-11 with respect to disbursement of open awards under the IRA or IIJA. Defendants are required to provide notice to agencies and grantees, and they must update the court on progress via status reports. The parties have since worked with the court to clarify requirements under the injunction, with the plaintiffs stating the Administration is not complying. The most recent status reports were filed on April 23, 2025.
The preliminary injunction order does not end the case but seeks to resolve short-term harms of frozen funds as the court process continues. This case and other litigation are part of a complex web of lawsuits over frozen funds and terminated grants playing out in multiple courts, with some outlets reporting more than 200 cases seeking to prevent Administration actions.
For more information, please contact Leigh Mitchell, USET SPF Senior Policy Analyst, at lmitchell@usetinc.org.
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