Trump Administration Regulatory Litigation Tracker

Our Trump Administration Regulatory Litigation Tracker briefly summarizes litigation over major executive actions of the new administration that are relevant to business, with links to key source documents such as presidential executive orders, complaints, briefs and court decisions. It is updated each Tuesday. However, there will be no update on April 29. For the latest Skadden analysis of the administration’s directives, see our Executive Briefing. 

The detailed case material below is organized by the subject of the executive action. The topics here are linked to headings below.

Regulatory Policy | Trade Policy | Energy and the Environment | Diversity, Equity and Inclusion | Federal Funding | Department of Government Efficiency | Federal Agencies | Federal Officials   

Significant developments between April 11 and April 18, 2025, include:

  • New executive orders and other administrative actions
    • Regulatory Policy: The president issued two executive orders to reduce federal contracting rules.
    • Regulatory Policy: The SEC issued a statement on “Offerings and Registrations of Securities in the Crypto Asset Markets.”
    • Regulatory Policy: The president issued an executive order to reduce “anti-competitive” regulations. The FTC issued a request for comment aligning with this order. The DOJ recently formed an “Anti-Competitive Regulations Task Force.”
    • Trade Policy: Customs and Border Protection issued guidance excluding certain categories of Chinese electronics from the 125% tariff rate imposed on Chinese goods.
    • Trade Policy: The president directed the Department of Commerce to investigate U.S. reliance on imported critical minerals.
  • Court decisions
    • Energy and Environment: A D.C. Circuit panel granted a stay of a lower court decision which had ordered Citibank to disburse funds from federal grants that the EPA sought to terminate. (D.C. Cir.)
    • Federal Agencies: The D.C. Circuit granted a partial stay of a district court preliminary injunction, allowing the administration to continue personnel cuts at the Consumer Finance Protection Bureau. (D.C. Cir.)
    • DOGE: A federal district court ordered the Office of Management and Budget and the Department of Government Efficiency to begin processing responsive documents for potential production in a suit seeking information on DOGE’s operations. (D.D.C.)
  • New litigations and appeals
    • Trade Policy: California filed a lawsuit in federal district court challenging the president’s use of the International Emergency Economic Powers Act (IEEPA) to impose tariffs on U.S. imports. (N.D. Cal.)
    • Trade Policy: The administration has filed motions to transfer two cases challenging tariffs from federal district courts in Montana and Florida to the Court of International Trade. (D. Mont.; N.D. Fla.)

Regulatory Policy

Executive Action: ‘10-1’ De-Regulation Order

Related Litigation

  • No pending cases at this time.

Executive Action: Regulatory Freeze

Related Litigation

  • No pending cases at this time.

Executive Action: Pausing Enforcement of the Foreign Corrupt Practices Act

Related Litigation

  • No pending cases at this time.

Executive Action: Review of Independent Agencies

Related Litigation

  • No pending cases at this time.

Executive Action: FCC Deregulatory Efforts

Related Litigation

  • No pending cases at this time.

Executive Action: Access to Agency Data

Executive Action: Financial Deregulation

Related Litigation

  •  No pending cases at this time.

Executive Action: DOJ Plan to Dissolve Tax Division

Related Litigation

  • No pending cases at this time.

Executive Action: Directive to Repeal Regulations Without Notice and Comment

Related Litigation

  • No pending cases at this time.

Executive Action: Crypto Deregulation and Enforcement Changes

Executive Action: Cutting Federal Contracting Rules

Related Litigation

  • No pending cases at this time.

Executive Action: Reducing Competition Regulations

Related Litigation

  • No pending cases at this time. 

Trade Policy

Executive Action: Tariffs Against China, Mexico and Canada

Related Litigation

  • Emily Ley Paper Inc v. Trump, No. 25-464 (N.D. Fla.)
    • Challenging the administration’s February and March tariffs on all imports from China, arguing that the president does not have authority to impose emergency tariffs without congressional approval
    • Complaint filed Apr. 3, 2025.
    • Motion to Transfer case to Court of International Trade filed by defendants Apr. 17, 2025

Executive Action: Tariffs on Steel and Aluminum

Related Litigation

  • No pending cases at this time.

Executive Action: Tariffs Against Imports From Countries Levying Digital Service Taxes on U.S. Technology Businesses

Related Litigation

  • No pending cases at this time.

Executive Action: Tariffs on Imported Cars and Parts

Related Litigation

  • No pending cases at this time.

Executive Action: ‘Reciprocal’ Tariffs

Related Litigation

Executive Action: Investigation of Critical Minerals Imports

Related Litigation

  • No pending cases at this time.

Energy and the Environment

Executive Action: Executive Orders Related to Energy

Related Litigation

Executive Action: Oil and Gas Development

Related Litigation

  • Northern Alaska Environmental Center v. Trump, No. 25-38 (D. Alaska)
    • Action seeking declaratory and injunctive relief to prevent injury from the Defendants’ promotion of gas and oil development and “unlawful attempt to undo permanent protections for certain areas of the U.S. Outer Continental Shelf in the Arctic Ocean, Pacific Ocean, Atlantic Ocean, and Gulf of Mexico”
    • Complaint filed Feb. 19, 2025

Diversity, Equity and Inclusion

Executive Action: Ending DEI Practices and Policies

Related Litigation

Federal Funding

Executive Action: Federal-Assistance Freeze

Related Litigation

Department of Government Efficiency

Executive Action: Establishing ‘Department of Government Efficiency’

Related Litigation

Executive Action: DOGE Access to Federal Payment System

Related Litigation

  • Alliance for Retired Americans v. Bessent, No. 25-313 (D.D.C.)
    • Action against Secretary of Treasury “for declaratory and injunctive relief to halt Defendants’ unlawful ongoing, systematic, and continuous disclosure of personal and financial information contained in Defendants’ records to Elon Musk and other members of the so-called ‘Department of Government Efficiency’ (DOGE), or to any other person”
    • Complaint filed Feb. 3, 2025
    • TRO filed Feb. 5, 2025; Memorandum of Support
    • Order entered on Feb. 6 converting motion for TRO to a motion for PI and approving a consent order that “Defendants will not provide access to any payment record or payment system of records maintained by or within the Bureau of the Fiscal Service, except that the Defendants may provide access to any of the following people: [Special Government Employees Tom Krause and now resigned Marko Elez, employees of the Dept. of the Treasury, or any other person normally entitled to access under U.S. Law and IRC].”
    • Minute Order entered on Feb. 25, 2025, stating that the court does have subject-matter jurisdiction and ordering the Defendants to produce their administrative record so the court may properly rendered its decision on the Motion for PI
    • Memorandum Opinion and Order entered Mar. 7, 2025, denying the Motion for PI
    • Motion to Dismiss or, in the Alternative, for Summary Judgment and Supporting Memorandum filed Apr. 11, 2025
  • State of New York v. Donald J. Trump, No. 25-1144 (S.D.N.Y.)
    • Lawsuit brought by a 19-state coalition, led by the New York Attorney General, seeking a request for an injunction blocking DOGE service temporary organization from having access to Department of Treasury payment systems.
    • Complaint filed Feb. 7, 2025
    • Memorandum ISO Motion for TRO filed Feb. 7, 2025
    • Order entered on Feb. 8, 2025, restraining the Trump administration from giving “political appointees” and “special government employees” access to Treasury payment records and systems, and says any previously obtained material must be “immediately” destroyed. The order also sets a hearing on Feb. 14, 2025, for defendant to show “why an order should not be issued pursuant to Rule 65 of the Federal Rules of Civil Procedure preliminarily enjoining the defendants during the pendency of this action[.]”
    • Order entered on Feb. 11, 2025, granting in part and denying in part the Emergency Motion to Vacate, clarifying the scope of the TRO
    • Opposition to Motion for PI filed on Feb. 11, 2025; Reply filed Feb. 13, 2025
    • Joint Letter filed on Feb. 14, 2025, explaining the parties’ positions in advance of the Feb. 14, 2025 motion for PI hearing
    • Opinion and Order entered Feb. 21, 2025, granting the Motion for PI, stating that Defendants “are restrained from granting access to any Treasury Department payment record, payment systems, or any other data systems maintained by the Treasury Department containing personally identifiable information and/or confidential financial information of payees to any employee, officer or contractor employed or affiliated with [DOGE,]” and ordering Defendants to submit a report to show that they are redressing APA violations to aid Court in deciding whether a preliminary injunction is still needed
    • Order entered Mar. 7, 2025, modifying the preliminary injunction to “exclude the PPS software application from the restrictions on access that were placed on employees, officers, or contractors employed or affiliated with the United States DOGE Service, DOGE, or the DOGE Team established at the Treasury Department”
    • Opinion and order granting Government’s motion to partially dissolve the preliminary injunction and denying Plaintiffs' motion for reconsideration entered Apr. 11, 2025

Executive Action: DOGE Access to Department of Labor Systems

Related Litigation

Executive Action: DOGE Access to Sensitive Personal and Financial Information

Related Litigation

Executive Action: DOGE Access to Internal Revenue Service Data

Related Litigation

Executive Action: DOGE Access to Social Security Administration Data

Related Litigation

Federal Officials

Executive Action: Termination of Agency Positions

Related Litigation

Federal Agencies

Executive Action: Dismantling of the Consumer Financial Protection Bureau

Related Litigation

Executive Action: Directing Agencies to Prepare for Reductions in Force (RIFs)

Related Litigation

Trump Executive Actions Advisory Group

If you have questions, please contact a member of our cross-practice team, which was created to help clients potentially affected by the administration's executive actions understand and implement the best ways to prepare for and respond to the evolving regulatory and legal landscape.They are listed here by subject area, along with a description of the group.

Related Capabilities

Antitrust/Competition // Artificial Intelligence // Consumer Financial Services // Cybersecurity and Data Privacy // Energy and Infrastructure Projects // Environmental // Financial Institutions Regulatory // Intellectual Property and Technology // Intellectual Property Litigation // International Litigation and Arbitration // International Trade // Labor and Employment Law // Life Sciences and Health Care // Litigation // National Security // SEC Reporting and Compliance // Securities and Commodities Enforcement // Supreme Court and Appellate Litigation // Tax // Web3 and Digital Assets // White Collar Defense and Investigations // Workplace Culture and Civil Rights/Racial Equity Audits

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