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. 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 June 20 and June 27, 2025, include:

  • New executive orders and other administrative actions
    • Regulatory Policy: After the Office of Comptroller of the Currency (OCC) rescinded a Biden-era bank merger rule related to the review of proposed transactions, legislation has now been passed preventing future reinstatement of the rule.
    • Regulatory Policy: The Federal Reserve issued a proposed rule, joined by the Federal Deposit Insurance Corporation (FDIC) and OCC, which would reduce leverage requirements at global systemically important banks with the goal of helping the Treasury market.
    • Trade Policy: The U.S. and China are reported to have finalized a trade agreement that will facilitate Chinese exports of rare earth minerals to the U.S.
    • Energy and the Environment: Citing President Trump’s executive order Unleashing Prosperity Through Deregulation, the Department of Agriculture rescinded a 2001 rule that had prohibited the development of roads on National Forest land. Environmental groups claim this will lead to an increase in logging and mining activities on Forest Service land.
  • Court decisions
    • Energy and the Environment: In a case brought by 14 states, a federal district court granted a motion for preliminary injunction blocking the Trump administration from withholding federal funding for electric vehicle charging infrastructure. (W.D. Wash.)
    • Trade Policy: The Supreme Court denied a petition for a writ of certiorari before judgment from the toy business plaintiffs in a case challenging the Trump administration’s emergency tariffs. This means that the Supreme Court will not expedite the case before it is reviewed by the D.C. Circuit. (SCOTUS)
  • New litigations and appeals
    • Energy and the Environment: The Michigan Attorney General and environmental groups have administratively challenged a Department of Energy (DOE) order to keep a coal power plant open past its planned retirement date. The Michigan AG and the groups argue that the energy crisis the DOE is using as a basis for the order is nonexistent.
    • Federal Funding: Attorneys General from 21 states and the District of Columbia brought an action challenging the Trump administration’s use of a clause in an OMB-promulgated regulation as justification to terminate billions in federal funding.

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: 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

Executive Action: Department of Labor Enforcement Changes

Executive Action: Designating Cartels and Other Organizations as Terrorists

Potential for Litigation

  • No pending cases at this time. 

Trade Policy

Executive Action: Tariffs Against China, Mexico and Canada

Related Litigation

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 and Other Executive Actions Related to Energy

Related Litigation

  • Climate United Fund v. Citibank, N.A., No. 25-5122, (D.C. Cir.)
  • United States v. State of Michigan, No. 25-496 (W.D. Mich.)
    • Action by the government seeking to block Michigan from threatened lawsuits against fossil fuel companies.
    • Complaint filed Apr. 30, 2025
    • Motion to dismiss for lack of jurisdiction filed on June 20, 2025
  • United States v. State of Hawaii, No. 25-179 (D. Hi.)
  • Action by the government seeking to block Hawaii from bringing a lawsuit against fossil fuel companies
  • United States v. State of Vermont, No. 25-463 (D. Vt.)
    • Action by the federal government targeting Vermont’s Superfund law
    • Complaint filed May 1, 2025
  • United States v. State of New York, No. 25-3656 (S.D.N.Y.)
    • Action by the federal government targeting New York’s Superfund law
    • Complaint filed May 1, 2025
    • Motion to Transfer filed June 13, 2025
    • Answer filed on June 20, 2025
  • State of New York v. Trump, No. 25-11221 (D. Mass)
    • Action by several states “to challenge President Trump’s unlawful Presidential Memorandum halting federal approvals of wind-energy development and to enjoin federal agencies’ implementation of that Memorandum”
    • Complaint filed May 5, 2025
    • Motion for PI and Supporting Memorandum filed by plaintiffs-states on May 12, 2025; Memorandum in Support filed May 14, 2025
    • Motion for PI and Supporting Memorandum filed by Alliance for Clean Energy New York on May 12, 2025; Opposition filed May 29, 2025; Reply filed June 3, 2025
    • Order filed June 5, 2025, collapsing the Motions for PI with a trial on the merits pursuant to Rule 65(a) and treating the oppositions to the Motions for PI as Motions to Dismiss
    • Amended Complaint filed June 10, 2025 o Supplemental Brief in Opposition to Motion to Dismiss filed by Alliance for Clean Energy New York on June 10, 2025
    • Supplemental Brief by Plaintiffs filed in opposition to Motion to Dismiss on June 11, 2025
    • Electronic clerk’s notes for proceedings entered June 18, 2025, stating that the “Court treats the opposition to the Motion for Preliminary Injunction as a Motion to Dismiss” and “allow[ing] the motion to dismiss in part and den[ying] the motion in part” with a written order to come
  • State of Washington v. U.S. Department of Transportation, No 25-848 (W.D. Wash.)
    • Action brought by 14 states seeking to block the Trump administration from withholding federal funding for electric vehicle charging infrastructure
    • Complaint filed May 7, 2025
    • Motion for PI filed by plaintiffs May 7, 2025; Response filed May 28, 2025; Reply filed June 4, 2025
    • Order granting in part and denying in part motion for PI entered June 24, 2025
  • State of Washington v. Trump, No. 25-869 (W.D. Wash.)
    • Action brought by several states “to protect the States—including their citizens and their natural resources—from the federal government’s unlawful use of emergency permitting procedures that bypass critical ecological, historical, and cultural resource review”
    • Complaint filed May 9, 2025
  • Lighthiser v. Trump, No. 25-54 (D. Mont.)
    • Action brought by young plaintiffs challenging the Trump administrations energy orders related to fossil fuel expansion. They argue that the orders worsen climate change violating their Fifth Amendment right to life and liberty while also arguing that the President exceeded his authority in disregarding environmental protection and health laws passed by Congress.
    • Complaint filed May 29, 2025
    • Motion for PI and supporting brief filed June 13, 2025
  • State of California v. United States, No. 25-04966 (N.D. Cal.)
    • Action brought by the State of California and 10 other states suing the Trump administration for signing resolutions repealing a waiver from California’s Clean Air Act, which permitted the state to impose its own vehicle emissions standards.
    • Complaint filed June 12, 2025
  • Air Alliance Houston v. Trump, No. 25-01852 (D.D.C.)
    • Action challenging the Trump administration’s April proclamation exempting certain coal-fired plants from complying with updates to the Mercury and Air Toxics Standards rule.
    • Complaint filed June 12, 2025

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; Answer filed May 7, 2025
    • Motion to Dismiss filed May 27, 2025
    • Amended Complaint filed June 16, 2025

Executive Action: Joint Investment Fund With Ukraine

Related Litigation

  • No pending cases at this time.

Executive Action: Nuclear Reactor Development

Related Litigation

  • No pending cases at this time.

Diversity, Equity and Inclusion

Executive Action: Ending DEI Practices and Policies

Related Litigation

  • National Urban League v. Trump, No. 25-471 (D.D.C.)
    • Action brought to “challenge Executive Order No. 14151 ‘Ending Radical and Wasteful DEI Programs and Preferencing’ ...; Executive Order No. 14168 ‘Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government’ ...; Executive Order No. 14173 ‘Ending Illegal Discrimination and Restoring Merit-Based Opportunity’ ...; and related agency actions, as ultra vires and in violation of the First and Fifth Amendments to the U.S. Constitution and the APA, and, accordingly, seek declaratory and injunctive relief.”
    • Complaint filed Feb. 19, 2025
    • Order entered Feb. 21, 2025, holding that the present case is not related enough to National Council of Nonprofits v. OMB, No. 25-239
    • Memorandum Opinion and Order denying Motion for PI entered May 2, 2025
    • Minute Order granting plaintiffs’ motion for leave to file an amended complaint entered May 20, 2025

Federal Funding

Executive Action: Federal-Assistance Freeze

Related Litigation

Executive Action: IRS Funding Cuts

Related Litigation

  • No pending cases at this time.

Executive Action: Federal Grant Cuts

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, 2025, 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; Cross Motion and Supporting Memorandum entered Apr. 25, 2025; Pl.’s Opposition filed Apr. 25, 2025; Reply re Motion to Dismiss filed May 9, 2025; Opposition to Cross-Motion for Summary Judgment filed May 9, 2025; Reply re Motion for Summary Judgment filed May 23, 2025
  • State of New York v. 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
    • Motion to Vacate the PI and Supporting Memorandum filed May 1, 2025; Opposition filed May 14, 2025; Reply filed May 21, 2025
      • Order denying Motion to Vacate entered May 27, 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

Executive Action: Creating New Federal Employment Classification

Related Litigation

  • No pending cases at this time.

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

BACK TO TOP