In a summary judgment on November 21 in Rhode Island v. Trump, Judge John J. McConnell Jr. ruled that the Trump administration’s attempt to shut down the Institute of Museum and Library Services (IMLS), along with other federal agencies, was illegal and unconstitutional.

McConnell’s ruling permanently enjoins the administration “from taking any future actions to implement, give effect to, comply with, or carry out the directives contained in the Reduction EO with respect to IMLS,” as well as the Minority Business Development Agency, the Federal Mediation and Conciliation Service, and the United States Interagency Council on Homelessness.

Shortly after President Trump issued a March 14 executive order that called for the elimination of IMLS and six other government agencies, two separate lawsuits were filed: American Library Association v. Sonderling by the American Library Association (ALA) and the American Federation of State, County and Municipal Employees; and Rhode Island v. Trump by a coalition of 21 state attorneys general.

Rhode Island v. Trump, filed on April 4, focused on the impact of closing IMLS and other agencies. McConnell was receptive to the plaintiffs’ argument that the executive order was unlawful and violated the Constitution, and that shuttering IMLS would “immediately put at risk hundreds of millions of dollars in grant funding on which the States depend, and undermine library programs, economic opportunity, and the free flow of commerce throughout the country.”

On May 13, McConnell issued a sweeping preliminary injunction ordering the administration to restore all IMLS staff to work and restore some of the terminated grants. The court also ordered Keith Sonderling, the Trump-appointed director of IMLS, to provide a status report detailing the agency’s compliance within seven days. The report indicated that staff were returning to work, and that three previously terminated FY24 Grants to States—California, Connecticut, and Washington—were reauthorized; Sonderling noted as well that partial FY25 payments to all state grantees had been authorized, pending apportionment from the Office of Management and Budget.

Defendants were denied a motion for a stay pending appeal on September 11; the court concluded that they failed to make a strong showing that they were likely to succeed on the merits of their appeal, demonstrate that states would not likely suffer substantial injury if the stay were issued, and show that the issuance of a stay was in the public interest.

In the case of ALA v. Sonderling, Judge Richard J. Leon granted a temporary restraining order to block the dismantling of IMLS, noting that “Plaintiffs have demonstrated irreparable injury.” The order prevented Sonderling from terminating staff but did not provide monetary relief to those states in which federal grants were canceled. On June 6, however, Leon declined to block the administration’s cuts to the agency while litigation continued. Temporarily halted by the government shutdown, the case is now scheduled to proceed. Congress will also be deciding, over the next few months, whether to fund IMLS in FY26.

For now, however, the administration is blocked from further action to shutter IMLS. McConnell’s decision laid out a range of harms that such actions would perpetuate, noting, “Given the ‘plethora of injuries’ that would arise if the Court did not grant injunctive relief, the balance of equities favors the States.”