Despite two Temporary Restraining Orders (TROs) issued by federal courts in Rhode Island and Washington, DC, the US District Court for the District of Rhode Island found that the Trump Administration’s funding freeze continues.  The court issued an Enforcement Order on February 10, 2025 repeating its mandate that the Administration return federal funding to the status quo pending the final outcome of the case. 

Previous Fox posts have tracked the litigation over the federal funding freeze pursuant to the Office of Management and Budget’s Memo (OMB Memo), and the resulting TROs.  Since then, plaintiff states in the Rhode Island litigation returned to court and filed an emergency motion to enforce the TRO on February 7, 2025, presenting evidence that the Administration had refused to disburse appropriated federal funds in compliance with the TRO. The defendants responded that any ongoing funding freezes were designed to root out fraud, not implement the OMB Memo or an Executive Order.  The court rejected the defendants’ claims, granting the plaintiffs’ motion for an Enforcement Order.  

The court defended its TRO as “clear and unambiguous,” finding that the Trump Administration had violated the TRO’s plain language that “Federal agencies cannot pause, freeze, impede, block, cancel, or terminate any awards or obligations on the basis of the OMB Memo, or on the basis of the President’s recently issued Executive Orders.”  The court also highlighted that the Administration could “request targeted relief from the TRO” on a specific showing that the funds were frozen under a valid authority (i.e., the Constitution, statute, regulation, etc.). 

For contractors and grantees, the Enforcement Order provides legal support for immediate access to any frozen funding.  Fox can provide advice about the next steps contractors and grant recipients should take to protect their financial interests.