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Judge Grants Preliminary Injunction Regarding OMB Memorandum M-25-13

See the latest developments regarding OMB Memorandum M-25-13.

On March 6, 2025, Judge John J. McConnell Jr. of the U.S. District Court of Rhode Island granted the State’s Motion for Preliminary Injunction.1 Relating to Memorandum M-25-13, which temporarily halted the disbursement of federal funds in January 2025,2 Judge McConnell found that the “categorical freeze of appropriated and obligated funds fundamentally undermines the distinct constitutional roles of each branch of our government.”

The March 6 Preliminary Injunction enjoins, or prohibits, any categorical funding freeze by the executive branch without congressional approval. Specifically, the court ordered the following:

  1. The OMB is “enjoined from reissuing, adopting, implementing, giving effect to, or reinstating under a different name the directives in OMB Memorandum M-25-13.”
  2. The OMB must provide written notice to all federal agencies and departments that they may not “take any steps to implement, give effect to, or reinstate under a different name.”
  3. The OMB must provide written notice to the agencies instructing them to “release and transmit any disbursements … on awarded grants, executed contracts, or other executed financial obligations.”

A preliminary injunction is issued in the early stages of a lawsuit to maintain the status quo until the lawsuit is resolved. It is temporary and serves to prevent potential harm while a case is ongoing.

Any questions from grant recipients should be directed to their respective agency’s general counsel.

  • 1“State of New York v. Trump, Order on Motion for Miscellaneous Relief AND Order on Motion for Preliminary Injunction — Document #161,” courtlistener.com, March 6, 2025.
  • 2“National Council of Nonprofits v. Office of Management and Budget (1:25-cv-00239),” courtlistener.com, March 7, 2025.

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