Take Care LedgerA dated, sourced record of the second Trump administration

Shutdowns, Rescissions and Impoundment Findings

Updated2026-11-09 Covers2025-01-20 to 2026-10-08

Summary

Between October 2025 and April 2026 the government had three funding lapses. A lapse, or shutdown, happens when Congress does not pass a spending bill in time. They included a 43-day full shutdown and a 76-day shutdown of the Department of Homeland Security (DHS), the longest on record.1,2,3,132 In January 2025 the Office of Management and Budget (OMB) paused federal financial assistance. Courts blocked the pause within days, and one judge found the administration had violated his order.62 OMB, led by Russ Vought, held back or cancelled money Congress had approved. It did this during lapses and near the end of fiscal years. That included about $28 billion for transit and energy projects in states that lean Democratic, in the first three days of the 2025 shutdown.4 The Government Accountability Office (GAO), Congress’s auditing arm, found nine violations of the Impoundment Control Act (ICA).41 That law bars the President from refusing to spend money Congress has approved without asking Congress first. GAO also concluded that the ICA did not allow two “pocket rescissions”. These were requests to cancel spending sent so late that the money expires before Congress’s review period ends.5,6,7,138 GAO’s top post, Comptroller General, has been empty since late 2025, and GAO has not sued to enforce any of these findings.8 On Sept 26, 2025 the Supreme Court paused a lower-court order to spend the money covered by the first pocket rescission.9

Background

The Impoundment Control Act of 1974 bars the executive branch from holding back money Congress has approved. The only exception is when it sends Congress a special message proposing to cancel the money.8 Congress then has 45 days to act, and the money must stay available in the meantime.6 The Antideficiency Act42 allows furloughs, or unpaid time off, during a lapse. But it bars spending without an appropriation, which is money Congress has approved by law.10 A 2022 law requires OMB to post apportionments within two business days. Apportionments are the documents that release money to agencies.11

Vought supported the “pocket rescission”. A 2018 GAO decision43 had found that the President has no power to hold back funds on his own.12 In April 2025, Comptroller General Gene Dodaro said GAO had 39 impoundment investigations open.8 Congress passed one ordinary rescission, which cut about $9 billion (Jul 24, 2025).13

What happened

The January 2025 assistance freezes

On Jan 27, 2025 acting OMB Director Matthew Vaeth sent agencies memo M-25-13. It told them to “temporarily pause all activities related to obligation or disbursement of all Federal financial assistance” that “may be implicated by” the President’s executive orders.62 On Jan 28, minutes before the pause took effect, Judge Loren AliKhan (D.D.C.) put it on hold for a short time. OMB withdrew the memo on Jan 29, and Press Secretary Karoline Leavitt posted that this was “NOT a rescission of the federal funding freeze.”62,85,86 On Jan 31, Chief Judge John McConnell Jr. (D.R.I.) granted 22 states and D.C. a temporary restraining order (TRO). A TRO is a short-term order that stops something while a judge looks at the case. McConnell wrote that the rescission “was in name-only,” and on Feb 10 he found the government had “continued to improperly freeze federal funds” in violation of his order. NBC News called this the first finding of the term that the administration had defied a court order.62,87,88 AliKhan (Feb 25) and McConnell (Mar 6) issued preliminary injunctions, orders that stop something until the case is decided. AliKhan found that agencies “were given roughly half a day to evaluate up to $3 trillion” in programs. The First Circuit refused to pause the orders on Mar 26.62,89,90,91

Section 7 of Executive Order 14154 (Jan 20, 2025) told all agencies to pause paying out funds Congress had approved under two laws. An executive order is a written order from the President to the agencies he runs. The two laws were the Inflation Reduction Act60 and the Infrastructure Investment and Jobs Act.61 An OMB and National Economic Council memo the next day told agencies to carry out the pause.34 On Apr 15, 2025 Judge Mary McElroy (D.R.I.) blocked the pause nationwide in Woonasquatucket River Watershed Council v. USDA46. She wrote, “The Court cannot see how they can claim that power”. The district court granted a request to enforce its order on Nov 4, 2025, and in 2026 the First Circuit upheld broad relief against the across-the-board freeze. That relief came under the Administrative Procedure Act44, the law that sets the rules agencies must follow. But the appeals court narrowed the orders that required payment.34,63

In the foreign-aid cases, Judge Amir Ali (D.D.C.) found on Feb 20 that the government had not fully obeyed his Feb 13 TRO. He did not hold it in contempt.64 On Mar 5, 2025 the Supreme Court ruled 5–4 in Department of State v. AIDS Vaccine Advocacy Coalition (No. 24A831)45. It refused to cancel Ali’s Feb 25 order to pay about $2 billion owed to foreign-aid contractors and grantees for completed work. It told the district court to make clear what the government had to do to comply. Justice Alito dissented, joined by Justices Thomas, Gorsuch and Kavanaugh. He asked whether “a single district-court judge who likely lacks jurisdiction” could force the payment.35 On Jul 21 Ali barred the government from giving effect to terminations issued before Feb 13.64 For the September 2025 pause in the same case, see Pocket rescissions below.

Apportionments and GAO findings

On Mar 24, 2025 OMB took down the apportionments website, calling the data “sensitive, predecisional.”11 Judge Emmet Sullivan ordered it restored (Jul 21, 2025). The D.C. Circuit refused OMB’s request to pause that order on Aug 9 and set an Aug 15 deadline to comply. OMB had restored the database by Aug 19.11,97,98,99 The restored records showed OMB making the release of funds depend on agencies following Trump’s executive orders.11,99 From May 22 to Sept 29, 2025 GAO found that agencies had broken the ICA by holding back several kinds of funds. These were electric-vehicle-charger funds (May 22), library and museum grants (June 16), Head Start (July 23) and part of the Energy Department’s Renew America’s Schools funds (July 31). They also included National Institutes of Health (NIH) grants (Aug 5) and Federal Emergency Management Agency (FEMA) disaster aid (in part on Sept 15, and on Sept 29). In the NIH decision, GAO noted that NIH committed about $8 billion less from February to June 2025 than a year earlier.8,102,103,104,105,106,107,108 Judge McConnell also heard the 21-state suit over the Institute of Museum and Library Services (IMLS). He ordered its staff and grants restored on May 13, 2025, and later ruled for the states without a trial. He permanently blocked the agency’s dismantling on Nov 21, and IMLS reinstated all of its grants on Dec 3.32,94,95,96 Judge Tana Lin (W.D. Wash.) ordered the Department of Transportation (DOT) on Jun 24, 2025 to release electric-vehicle-charger formula money to 14 of the 17 states that sued. DOT issued guidance on Aug 15 that restarted the program after a six-month freeze. Transportation Secretary Sean Duffy said, “While I don’t agree with subsidizing green energy, we will respect Congress’ will.”33,92,93

On Sept 26, 2025 OMB told the Council of the Inspectors General on Integrity and Efficiency (CIGIE) that, as “a policy decision,” it would not release the council’s FY2026 funds. CIGIE is the group of inspectors general, the independent watchdogs inside agencies. By Oct 1 Oversight.gov and at least 15 inspector-general websites were offline. Senators Susan Collins and Chuck Grassley asked Vought for his legal authority. After that, OMB released part of the funds.36,126,127,128

On June 4, 2026 GAO concluded in a legal decision (B-337838)54 that the Energy Department “is required to obligate and expend” funds at the control-point levels Congress carried into FY2025. Control points are spending levels Congress set for specific programs. The appropriators who asked for the decision said DOE’s spending plan cut wind from $137 million to $29.8 million. They said it cut solar from $318 million to $41.9 million.39 GAO made no final violation finding because DOE did not identify where its funding came from. GAO said DOE should report an Antideficiency Act violation to the extent it went over the limits.39 On Sept 17, 2026 Judge Allison Burroughs (D. Mass.) ruled on OMB’s apportionment footnotes. The footnotes made Institute of Education Sciences funds depend on following Executive Orders 14151 and 14332, and she canceled them. She held that OMB went beyond the authority the law gives it and acted arbitrarily and capriciously, meaning without a reasonable explanation. She rejected the argument that the Antideficiency and Impoundment Control Acts bar courts from reviewing the issue.40 GAO issued its eighth and ninth ICA findings on Oct 7, 2026.5

Pocket rescissions

On Aug 29, 2025 the White House proposed cancelling $4.9 billion across 15 accounts, mostly foreign aid.6,12 The money expired Sept 30, before the 45 days ended.6 GAO said the ICA “does not permit the withholding of funds past their date of expiration.”6 On Sept 26 the Supreme Court paused an order to spend about $4 billion in expiring aid. It acted on its emergency docket, where it decides cases quickly, often without full argument. It held that the ICA likely bars suits under the Administrative Procedure Act (APA).9 Justices Kagan, Sotomayor and Jackson dissented.9

On Sept 25, 2026 Vought proposed cancelling about $810 million five days before it expired.7 GAO said on Sept 29: “The President may not force the expiration of budget authority Congress has already enacted and did not rescind.”138 Vought said GAO had become “hyper partisan”. Senate Appropriations Chair Susan Collins (R) called the action illegal.138

The October–November 2025 shutdown

OMB told agencies to draft plans for layoffs during a shutdown. On Sept 30, 2025 Trump said those laid off would be “Democrats.”10 The funding fight centered on extending enhanced Affordable Care Act (ACA) premium credits, which lower the cost of health plans bought on the ACA marketplaces.10 The shutdown began Oct 1.1 Within three days the administration froze or cancelled about $28 billion for transit and energy in states that lean Democratic.4 Trump called the lapse an “unprecedented opportunity”. He said he would meet Vought to decide which “Democrat Agencies” to cut.4 OMB sent layoff notices to more than 4,000 workers (Oct 10). More than 1,000 were at the Department of Health and Human Services (HHS), mostly at the Centers for Disease Control and Prevention (CDC). About 600 CDC workers remained fired as of Oct 14. Judge Susan Illston issued a TRO blocking the layoffs (Oct 15).14,65,129

Trump ordered troops paid from about $8 billion in Pentagon research funds that had not yet been committed (Oct 11).15 The Pentagon also accepted a $130 million gift, about $100 per service member, from Timothy Mellon. The New York Times identified him as the top outside-spending donor of the 2024 election cycle.16 The Agriculture Department (USDA) said November Supplemental Nutrition Assistance Program (SNAP) benefits, which help families buy food, would not go out.17 On Oct 31 Judge McConnell ordered USDA to pay them from its contingency fund, money set aside for emergencies. Judge Talwani found the suspension likely unlawful. The Supreme Court paused the order to pay full benefits (Nov 7, extended Nov 11).17,18 USDA paid 65% of the maximum benefit, and some households received nothing. USDA told states to issue full benefits Nov 13, after the government reopened.19

On Nov 7 Judge Christopher Cooper (D.D.C.) ruled on the Education Department’s out-of-office emails. The department had replaced furloughed employees’ own replies with a message blaming “Democrat Senators” for the lapse. He held that this violated the First Amendment,47 which protects free speech. He permanently barred partisan edits to union members’ automatic replies.37 The Office of Special Counsel received more than 1,000 complaints about shutdown messages from the White House and 37 agencies. On Sept 25, 2026 it declined to discipline agencies under the Hatch Act,66 a law that limits political activity by federal employees on the job. It said the agencies had relied on a 2024 advisory opinion. But it warned that “derogatory tone and broad dissemination” may show a banned election purpose.67

The shutdown ended Nov 12, 2025 with a stopgap spending bill. The bill funded SNAP through September 2026 and reversed about 4,000 layoffs. The ACA credits expired Dec 31.1,20,130,21 Judge Illston blocked a State Department round of layoffs of about 250 Foreign Service and civil service employees (Dec 4). On Dec 17 she ordered all layoffs made during the shutdown canceled, with back pay. The government appealed.131,22

The 2026 lapses and stopgap

Customs and Border Protection (CBP) agents killed Alex Pretti in Minneapolis. After that, Democrats would fund DHS only if Immigration and Customs Enforcement (ICE) and CBP made changes. On Feb 6 they named the changes: judicial warrants, a ban on agents’ face masks, body cameras and visible identification. The dispute led to a partial lapse (Jan 31–Feb 3, 2026) and the DHS-only shutdown (Feb 14–Apr 30, 2026).3,132,2,117 More than 1,110 Transportation Security Administration (TSA) officers quit.2 DHS suspended Global Entry on Feb 22 and reversed a planned suspension of TSA PreCheck. FEMA stopped responses that were not for disasters. ICE and CBP kept operating on 2025 reconciliation funds, money from a special budget law. On Mar 27 Trump signed an executive order directing DHS to pay TSA officers during the lapse.2,118,119 The House passed the Senate’s DHS bill by voice vote, and Trump signed it on Apr 30, ending the lapse without the enforcement changes Democrats had sought.2,120 A stopgap signed Sept 2, 2026 funds the government to Dec 11.27,28

Grants withheld, conditioned or terminated

For the $28 billion frozen in October 2025, see the 2025 shutdown above. CNN reported that Trump offered to release frozen Hudson Tunnel money if Penn Station and Dulles Airport were renamed for him.23 Construction stopped on Feb 6, 2026, idling 1,000 workers. That happened after DOT held back $205 million under the October 2025 freeze. Hours later Judge Jeannette Vargas (S.D.N.Y.) ordered the funds released. The Transportation Department released $127 million (Feb 18, 2026), and Gov. Kathy Hochul said construction would resume the following week.23,112,113 On Jun 29 Vargas entered final judgment for New York and New Jersey. She held that the suspension broke the Uniform Grant Guidance, the federal rules for managing grants. The administration told the court on Aug 28 that it would appeal to the Second Circuit. It agreed on Sept 18, 2026 to dismiss the appeal.114,115,116 Thirteen states sued Energy Secretary Chris Wright and OMB over the cancelled energy and infrastructure awards on Feb 18, 2026 (California v. Wright, N.D. Cal.). They claimed violations of the APA, the First Amendment, the Fifth Amendment and the separation of powers. The court refused to dismiss the case on June 2.77 Wright told the House Science Committee on June 10 that the cancellations were not political. In a court filing on Jul 15, 2026, the Energy Department stated that 284 grants OMB cut were chosen “based solely on the political identity” of the recipients’ states.25,137

Trump said agencies should stop paying “sanctuary” jurisdictions, places that limit their help with federal immigration enforcement. After that, OMB directed the CDC to cancel about $602 million in grants to California, Colorado, Illinois and Minnesota. HHS told Congress on Feb 9 the grants were “inconsistent with agency priorities.”38 Judge Manish Shah (N.D. Ill.) issued a TRO on Feb 12, 2026. He wrote that officials’ statements “plausibly suggest that the reason for the direction is hostility to what the federal government calls ‘sanctuary jurisdictions,’” in that ruling. On Mar 12 he issued a preliminary injunction against the OMB directive to HHS. He did not block the broader directive to many agencies.38,134 Health and Human Services (HHS) withdrew a $10 billion childcare freeze on five states led by Democrats after several court losses (Jul 13, 2026).24

The Transportation Department (DOT) made a rule limiting “non-domiciled” commercial driver’s licenses held by immigrants. These are licenses for drivers whose permanent home is not in the state. The D.C. Circuit paused the rule on Nov 13, 2025, finding DOT had not explained how it would make roads safer. DOT held back $200 million from California. On Apr 16, 2026, it held back $73.5 million from New York for refusing to revoke about 33,000 such licenses. New York asked the Second Circuit on Apr 24 to restore the money.73,109,110,111 The Centers for Medicare & Medicaid Services (CMS) delayed $243.8 million in Minnesota Medicaid payments across 14 services. It labeled those services “high-risk” for fraud. The money would be released once the state adopted a “comprehensive corrective action plan”. On Apr 6 Judge Eric Tostrud (D. Minn.) denied the state emergency relief. He held that the claim was premature, because no cut had been finalized.74,135 On May 7 the court paused the case at both sides’ request. It has not ruled on the main claims.139

An Associated Press (AP) analysis found Trump approved about 80% of Republican governors’ disaster requests and 60% of Democratic governors’. On Jul 3, 2026 he denied “Blizzard of 2026” requests from Massachusetts, New Jersey, New York and Rhode Island. Those states had sought $227 million. FEMA regional offices had certified that their requests met federal thresholds.26,125

On Apr 1–3, 2025 the Department of Government Efficiency (DOGE) cancelled about 1,400 National Endowment for the Humanities (NEH) grants. The grants covered more than $100 million that Congress had approved. Before that, NEH chair Shelly Lowe was pushed out “at the direction of President Trump” on Mar 12, and NEH staff were cut.78,100 On Mar 20, 2026 the Underground Railroad Education Center in Albany sued NEH over the cancellation of a $250,000 grant. The grant was for an interpretive center beside the Stephen and Harriet Myers Residence. The center asked to get the money back. It argued under the First Amendment (viewpoint discrimination, meaning treating people differently because of their views) and the Fifth Amendment (racial discrimination).79 The complaint was filed by Lawyers for Good Government. It says the administration “systematically targeted grantees and programs that sought to increase the public’s understanding” of Black history. The White House did not respond to NBC’s request for comment, and no ruling has been found.79 On May 7, 2026 Judge Colleen McMahon (S.D.N.Y.) ruled in suits by the American Council of Learned Societies, the American Historical Association, the Modern Language Association and the Authors Guild. She ruled that the NEH cancellations broke the First Amendment’s bar on viewpoint discrimination. She found they also broke the Fifth Amendment’s guarantee of equal protection, and that no law authorized them. She found that DOGE, not NEH, had carried them out.78,101 Sworn testimony showed that the DOGE staffers who flagged the grants, identified as Justin Fox and Nate Cavanaugh, never read the applications. They used ChatGPT to write reasons for cancelling based on diversity, equity and inclusion (DEI). McMahon noted they were in their 20s and “did not have much experience in anything at all.”78,101

On Mar 16, 2026 sixteen attorneys general sued the Department of Housing and Urban Development (HUD) in the N.D. Cal. They challenged conditions on Fair Housing Assistance Program (FHAP) funds, which pay state and local agencies to enforce fair-housing law.80 California Attorney General (AG) Rob Bonta and Illinois AG Kwame Raoul led the suit. Arizona, Colorado, Connecticut, Delaware, D.C., Hawaii, Maine, Maryland, Massachusetts, Michigan, New Jersey, Rhode Island, Vermont and Washington joined it.80 HUD’s September 2025 guidance threatened to decertify agencies that enforced protections beyond the federal Fair Housing Act. That would cut off their complaint referrals and funding. The guidance also barred them from bringing disparate-impact claims, which challenge practices that harm a protected group even without intent to discriminate. It barred them from using funds to “subsidize” or “promote” illegal immigration and from promoting “gender ideology.”80 The states brought claims under the APA, the Constitution, HUD’s own regulations and the Fair Housing Act. Secretary Scott Turner called the suit “political lawfare.”80 In a letter dated Sept 2, 2026 HUD said it would not impose, carry out or enforce the challenged conditions, now or in future guidance. It said they would not apply to FY2026 funding. The parties agreed to dismiss the case without prejudice, meaning it could be filed again. The Vermont AG announced this on Sept 8.80,123,124

On Mar 23, 2026 twenty states and D.C. sued the Agriculture Department (Massachusetts v. USDA, D. Mass. No. 1:26-cv-11396). They challenged the General Terms and Conditions that Secretary Brooke Rollins issued in a Dec 31, 2025 memo. The memo said USDA grants will “advance policies that put America first”. The conditions govern about $74 billion a year in federal funds.81 They apply to new awards starting 45 days after the memo. They bar funding for DEI programs, aid to “illegal aliens,” “gender ideology,” male participation in women’s sports and foreign “dangerous gain-of-function research,” and they add a “buy American” requirement.81 The states argue that the conditions are vague, coercive and unrelated to the programs. They make these claims under the APA and under the Spending Clause, the part of the Constitution that lets Congress tax and spend. The programs are mostly food assistance, but they also fund farm research and wildfire prevention.81 Washington AG Nick Brown said “threatening to withhold food assistance from kids and vulnerable families is heartless and against the law”. USDA declined to comment.81 On June 5, 2026 the court issued a preliminary injunction barring USDA from enforcing the challenged conditions. Its June 24 written decision found the states likely to win on their Spending Clause theories. It also found them likely to win their APA claim that the conditions were arbitrary and capricious. The government asked the court to dismiss the case on July 10, and the states amended their complaint on Aug 14.81

Consumer Financial Protection Bureau funding

The Consumer Financial Protection Bureau (CFPB) is not funded by yearly spending bills. Instead, its director requests transfers from the Federal Reserve. Acting Director Vought stopped requesting them. He relied on a November 2025 opinion from the Office of Legal Counsel (OLC), the Justice Department office that gives the executive branch legal opinions. It said the Fed had no “combined earnings” because it had run losses since September 2022. Judge Amy Berman Jackson (D.D.C.) rejected that reading on Dec 30, 2025. She held that the phrase means gross earnings, meaning earnings before expenses are subtracted.71 Judge Edward Davila (N.D. Cal.) ruled on Mar 13, 2026. He held that Vought had acted “arbitrarily, capriciously and contrary to law,” and he called the plan a “transparent attempt to ‘close down the agency’,” in the same ruling. He permanently ordered the director to request each quarter the amount “reasonably necessary” for the bureau’s duties. The CFPB appealed to the Ninth Circuit on May 11.72,121 On Sept 25, 2026 Judge Ann Aiken (D. Or.) ruled in State of New York v. Vought, a suit by a group of 21 states and D.C. She held that “combined earnings” means gross revenue. She canceled Vought’s decisions not to request funds, finding they violated the APA and the separation of powers. She declined to issue an injunction for fiscal 2026 because the year was ending.71,122

Key dates

Why it matters

Appropriations Clause and Impoundment Control Act (Art. I §9 cl. 7; 2 U.S.C. §§681–688). The Constitution says Congress decides how public money is spent. Under the Appropriations Clause (Article I, §9, Clause 7),48 the executive branch may spend only what Congress has approved by law. Congress’s spending power in Article I49 also places spending decisions with Congress. The Impoundment Control Act, 2 U.S.C. §§681–688, requires a special message for any proposed rescission, which is a request to cancel approved spending. It keeps the funds available for 45 days of continuous session while Congress considers the request. The legal question is whether a special message sent too late for the 45 days to run before the funds expire lets the money lapse lawfully. The record here does not include the administration’s stated legal basis for the timing. Vought’s recorded response to GAO’s 2026 decision was that GAO had become “hyper partisan.”138 GAO concluded in two legal decisions, B-337805 (2025)51 and B-338788 (Sept 29, 2026)52, that the ICA does not allow it.6,138 The Supreme Court’s Mar 5, 2025 order in Department of State v. AIDS Vaccine Advocacy Coalition left in place an order to pay for completed foreign-aid work. OMB called its refusal to release CIGIE’s funds “a policy decision,” and GAO’s June 2026 Energy decision held that the department must commit funds at the control-point levels Congress set.35,36,39 As a result, about $4.9 billion in 2025 and about $810 million in 2026 expired without being spent.6,30

Who may sue to enforce the ICA (2 U.S.C. §687; 31 U.S.C. §703; 5 U.S.C. §§701–706). The ICA lets the Comptroller General sue to force the release of funds (2 U.S.C. §687)50. GAO has found nine ICA violations in 2025–26 without suing.5 The power to sue belongs to the Comptroller General, the head of GAO. The post has been empty since Gene Dodaro’s term ended in late 2025. A congressional commission must recommend at least three candidates for the post (31 U.S.C. §703)69. It had not met by Oct 8, 2026, and the White House was reported to be considering OMB Deputy Director Eric Ueland.70 In its Sept 26, 2025 order pausing the lower court in Department of State v. AIDS Vaccine Advocacy Coalition53, the Supreme Court held that the ICA likely bars APA suits by private parties. Three justices dissented.9 Lower courts have still granted relief in suits by states and grantees. They blocked the January 2025 assistance pause, the EO 14154 pause and OMB’s CDC directive. They canceled OMB’s apportionment conditions on education-research funds, while rejecting the argument that the ICA bars review. They also ordered EV-charger, library-grant and tunnel funds released.62,34,38,134,40,33,32,23,92,94,112

CFPB funding statute (12 U.S.C. §5497(a)(1)). The statute75 funds the CFPB by transfer “from the combined earnings of the Federal Reserve System” of the amount the director decides is “reasonably necessary.” The question is whether a director may stop the transfers by giving a new meaning to “combined earnings.” Three district courts have read the phrase as gross earnings and ruled against Vought. Appeals are pending in the D.C. and Ninth Circuits.71,72,121,122

Antideficiency Act and Purpose Statute (31 U.S.C. §§1301(a), 1341–1342). The Antideficiency Act, 31 U.S.C. §§1341–1342, bars agencies from committing money before Congress approves it. It also bars accepting unpaid volunteer work except in emergencies. The Purpose Statute, 31 U.S.C. §1301(a)55, says money may be used only for the purposes Congress set. One question is whether a lapse allows layoffs (reductions in force) rather than furloughs, as OMB’s Sept 24, 2025 memo had planned. That question was not decided on the merits. The layoffs were blocked, then reversed by the reopening law and Judge Illston’s Dec 17 order. The government withdrew the guidance in a settlement around Sept 23, 2026.10,14,129,130,22,31 A second question is whether two kinds of payments follow the Purpose Statute and the Antideficiency Act: paying troops from research funds, and paying TSA officers by executive order. Another is whether accepting a private gift to cover military pay fits the Pentagon’s power to accept gifts. The Pentagon said it accepted the gift under its “general gift acceptance authority.”15,16,119 No court or GAO ruling on those payments had been located as of Nov 8, 2026.

First Amendment and Hatch Act (5 U.S.C. §7323(a)(1)). Judge Cooper ruled on messages during a lapse (Nov 7, 2025). He held that the First Amendment barred the Education Department from putting partisan shutdown messages in career employees’ automatic replies. The Office of Special Counsel declined to discipline agencies under the Hatch Act for their shutdown messages. But it warned that similar messages could violate 5 U.S.C. §7323(a)(1), which bars using official authority to affect an election (Sept 25, 2026).37,67

First and Fifth Amendments, Spending Clause and Stafford Act (allocation by state). The First Amendment and the equal-protection part of the Fifth Amendment’s Due Process Clause56 govern whether federal awards may be ended for partisan reasons. The Stafford Act,57 the main federal disaster law, leaves major-disaster declarations to the President’s discretion. The Energy Department’s July 15, 2026 filing stated that its 284 cancellations were not “based on any programmatic, statutory, cost-reduction, or performance-based factor,” and those cancellations remain in court. House Science Committee Democrats referred Wright to the Justice Department on Aug 4, 2026, alleging his June testimony was false. A federal law makes false statements to Congress a crime (18 U.S.C. §100158).25,137 Citizens for Responsibility and Ethics in Washington (CREW) filed a Hatch Act complaint over the cancellations on Sept 9, 2026, citing DOE’s admission.68 Minnesota argued that the Medicaid delay imposed funding conditions after the fact. New York argued that DOT’s withholding pressures it into canceling valid licenses. Under the Spending Clause rule of Pennhurst State School & Hospital v. Halderman (1981)76, Congress must set grant conditions “unambiguously.” Judge Tostrud found the delay likely complies with the governing regulations.74,135,73 For the CDC directive, Judge Shah wrote that officials’ statements “plausibly suggest” hostility to sanctuary jurisdictions as its reason. HHS told Congress the grants were “inconsistent with agency priorities.”38 For the Hudson Tunnel and the blizzard-aid denials, the record here does not include the administration’s stated legal basis. Judge Jeannette Vargas found “the public interest would be harmed by a delay in a critical infrastructure project,” and ordered the funds released. Her Jun 29, 2026 final judgment held that the suspension violated the Uniform Grant Guidance.23,26,112,114

Spending Clause conditions and viewpoint-based grant terminations (Art. I §8 cl. 1; First and Fifth Amendments). Under the spending power,49 three Supreme Court cases set limits. Pennhurst76 requires Congress to state grant conditions clearly. South Dakota v. Dole (1987)82 requires conditions to relate to the federal interest in the program. NFIB v. Sebelius (2012)84 bars money pressure so coercive that it leaves states no real choice. The states suing USDA argue that its “America first” conditions are vague, coercive and unrelated to food assistance, farm research and wildfire programs. USDA declined to comment. On June 5, 2026 the court issued a preliminary injunction against the conditions. It found the states likely to win on their Spending Clause theories and their APA claim that the conditions were arbitrary and capricious.81 The HUD suit also turned on the Fair Housing Act. Under Texas Dept. of Housing & Community Affairs v. Inclusive Communities Project (2015),83 disparate-impact claims can be brought under that law. HUD withdrew its bar on such claims and its other conditions before any ruling. So no court decided whether they were lawful.80 On cancellations, Judge McMahon held on May 7, 2026 that DOGE’s NEH cancellations were viewpoint discrimination barred by the First Amendment. She held they violated the Fifth Amendment’s guarantee of equal protection and that no law authorized them. The Underground Railroad suit raises the same two constitutional claims for one grant and had no ruling.78,79

Outcome

Where things stand

All three lapses ended through laws passed by Congress. The current stopgap runs to Dec 11, 2026.1,3,133,2,27,28 The lame-duck session, the period after the election and before a new Congress, opens Nov 9. By then the House will have passed 3 of 12 fiscal 2027 spending bills, and the Senate none. The reported options are another stopgap into 2027, one large spending bill (an omnibus), several smaller ones (minibuses), or a partial lapse.28

SNAP households received partial benefits for November 2025. After the credits expired, ACA marketplace net premiums rose about 58%, according to KFF, a health policy research group. About 4,000 workers received layoff notices that were later reversed. More than 1,110 TSA officers quit during the DHS lapse. Tunnel construction stopped Feb 6, 2026 until funds were released.19,21,1,2,23 In September 2026, HUD dropped its fair-housing funding conditions. A court issued a preliminary injunction against USDA’s grant conditions on June 5, 2026, and no ruling was found in the Underground Railroad Education Center’s NEH suit.80,81,79 Several things were not located as of Nov 8, 2026. These include any court or GAO ruling on troop pay, the Mellon gift or TSA pay, and later appeal outcomes in the January 2025 freeze cases. They also include Office of Special Counsel (OSC) action on CREW’s DOE complaint, and how the Dec 11 deadline is resolved.

Status

Item Status Latest development (date) What would change it
Funding lapses (2025 shutdown; 2026 partial and DHS lapses) Concluded All ended by laws passed by Congress; the DHS lapse on Apr 30, 20261,3,133,2,120 —
FY2027 appropriations Pending (Congress; stopgap expires Dec 11, 2026) Stopgap signed Sept 2, 202628 A lame-duck stopgap, omnibus, minibuses or a partial lapse28
ICE and Border Patrol funding In force $70 billion package funds them through Trump’s term (Jun 10, 2026)29,136 —
Pocket rescissions ($4.9 billion, 2025; ~$810 million, 2026) Concluded Funds expired Sept 30, 2025 (after the Supreme Court’s pause) and Sept 30, 2026; no suit or vote on the second reported as of Oct 156,9,30 —
GAO’s nine ICA violation findings Unresolved Eighth and ninth issued Oct 7, 2026; no suit to enforce them5 A Comptroller General suit under 2 U.S.C. §68750
Comptroller General vacancy Pending (31 U.S.C. §703 commission; no date) Commission had not met as of Oct 8, 2026; career staff lead GAO in acting roles70 A commission recommendation and a nomination69
Shutdown layoffs and layoff (RIF) guidance Reversed Illston ordered all layoffs canceled Dec 17, 2025; guidance withdrawn in the ~Sept 23, 2026 AFGE v. OMB59 settlement22,31 Another lapse before year-end, while the case stays open31
November 2025 SNAP benefits; ACA credits Concluded SNAP paid at 65%, then in full after Nov 13, 2025; credits expired Dec 31, 202519,21 —
Troop pay, Mellon gift and TSA pay Unresolved No court or GAO ruling located as of Nov 8, 202615,16,2 —
Partisan shutdown messages Blocked (Judge Cooper, Nov 7, 2025, for Education Department automatic replies) OSC declined Hatch Act discipline, with a warning (Sept 25, 2026)37,67 —
January 2025 freezes (M-25-13, EO 14154, foreign aid) Blocked (injunctions Feb 25 and Mar 6, 2025; Woonasquatucket, Apr 15, 2025; Judge Ali, Feb 25, 2025) First Circuit upheld the APA relief against the EO 14154 pause in 2026, narrowing payment orders62,34,35 Later appeal outcomes (not verified)
Apportionments site; library and EV-charger funds Blocked (court orders) Database restored by Aug 19, 2025; charger program restarted Aug 15, 2025; IMLS dismantling permanently blocked Nov 21 and grants reinstated Dec 3, 202511,99,93,95,96,32,33 —
Hudson Tunnel funds Concluded $127 million released Feb 18, 2026; final judgment for New York and New Jersey Jun 29; appeal dropped by agreement Sept 18, 202623,113,114,116 —
CIGIE apportionment Reversed (in part) OMB released part of the funds128 —
Education-research apportionment footnotes Blocked (Judge Burroughs, Sept 17, 2026) Canceled; claim over funds expiring Sept 30 put off40 —
Energy control-point spending Unresolved GAO B-337838 (June 4, 2026): DOE should report Antideficiency Act violations to the extent it went over the limits39 —
HHS $10 billion childcare freeze Reversed Withdrawn Jul 13, 202624 —
CDC $602 million grant terminations Blocked (Judge Shah, preliminary injunction, Mar 12, 2026) Broader directive to many agencies not blocked134 —
Energy’s 284 grant cancellations Pending (California v. Wright, N.D. Cal.) Request to dismiss denied June 2, 2026; Wright referred to the Justice Department Aug 477,137 A ruling on the merits; OSC action on CREW’s complaint68
Blizzard-aid denials to four states In force Denied Jul 3, 202626,125 —
DOT highway funds (California, New York) Pending (Second Circuit) New York petitioned Apr 24, 2026; no ruling reported73,111 Second Circuit ruling73
Minnesota Medicaid deferral In force Emergency relief denied Apr 6, 2026; case paused at both sides’ request, no ruling on the main claims (May 7, 2026)135,139 A state corrective action plan74
NEH grant terminations (~1,400 grants) Blocked (Judge McMahon, S.D.N.Y., May 7, 2026) Cancellations held unconstitutional and not authorized by any law78,101 An appeal
Underground Railroad Education Center NEH grant ($250,000) Pending (federal court; no date) Suit filed Mar 20, 2026; no ruling found79 A ruling on getting the money back
HUD fair-housing (FHAP) funding conditions Reversed HUD dropped the conditions by letter (Sept 2, 2026); suit dismissed without prejudice (Sept 8)80,123,124 New conditions in later guidance
USDA standard grant conditions (~$74 billion a year) Blocked (Massachusetts v. USDA, D. Mass., preliminary injunction, June 5, 2026) Written decision June 24; government asked to dismiss July 10; states amended their complaint Aug 14, 202681 A ruling on the merits of the Spending Clause and APA claims
CFPB funding requests Blocked (Judge Davila, permanent injunction, Mar 13, 2026) Ninth Circuit appeal filed May 11; Judge Aiken canceled the refusals Sept 25, 2026; appeals pending72,71,121,122 Ninth and D.C. Circuit rulings72,71

Who is affected

Funding lapses affected households that get Supplemental Nutrition Assistance Program (SNAP) benefits and federal employees sent layoff notices. They also affected Transportation Security Administration (TSA) officers during the Department of Homeland Security (DHS) lapse, and service members paid from other accounts.19,14,2,15 Enhanced Affordable Care Act (ACA) premium credits were the issue at the center of the 2025 funding fight. Their expiration affected people who buy plans on the marketplaces.10,21 Funds that were held back, given conditions or cancelled affected foreign-aid grantees, states, transit and energy projects and public-health departments. They also affected childcare and Medicaid programs, states hit by disasters and humanities grantees. That included about $28 billion frozen or cancelled in states that lean Democratic in the first three days of the 2025 shutdown.35,4,23,38,24,74,26,78

Key players

Related: Federal Workforce Reductions and Schedule F, Musk, DOGE and Conflict-of-Interest Questions, Outside Allies and Donors, City Enforcement Operations and Fatal Shootings, Detention and Deaths in Custody, Withdrawn Studies and Deleted Federal Data, Renamings, Monuments and the Ballroom and The 2026 Midterms.

Chronology

Sources


  1. NBC: Trump signs funding bill, ending record-long government shutdown · Timeline 2025-10-01 → ledger ↩↩↩↩↩↩↩

  2. Politico: Congress ends record-shattering DHS shutdown · Timeline 2026-02-14 → ledger ↩↩↩↩↩↩↩↩↩↩↩↩

  3. NPR: Senate shutdown vote fails · PBS NewsHour (AP): Here’s what to know about the partial government shutdown and its impact · NBC News: Trump signs bill to end government shutdown and fund DHS for two weeks · Timeline 2026-01-29 → ledger ↩↩↩↩

  4. CNBC: Trump admin freezes $2.1 billion for Chicago projects, blames Democrats · Timeline 2025-10-01 → ledger ↩↩↩↩↩

  5. GAO: EPA Community Change Grants decision (B-337485) · GAO: Impoundment Control Act decisions · Timeline 2026-10-07 → ledger ↩↩↩↩

  6. GAO: Review of the President’s Special Message of Aug 28, 2025 (B-337805) · Timeline 2025-08-29 → ledger ↩↩↩↩↩↩↩↩↩

  7. GAO: Review of the President’s Special Message of Sep 25, 2026 (B-338788) · Roll Call: Trump’s funding cancellation violates budget law, GAO says · Timeline 2026-09-25 → ledger ↩↩↩↩

  8. GAO: Impoundment Control Act decisions · Federal News Network: GAO finds second violation of spending law · Timeline 2025-05 (late) → ledger ↩↩↩↩↩

  9. Supreme Court: Department of State v. AIDS Vaccine Advocacy Coalition, 25A269 (PDF) · SCOTUSblog: Supreme Court allows administration to withhold foreign aid · Timeline 2025-09-26 → ledger ↩↩↩↩↩↩

  10. NBC News: White House lays groundwork for mass government firings if there’s a shutdown · Government Executive: Government spirals into shutdown with Trump promising mass layoffs · TIME: Trump doubles down amid government shutdown as layoffs loom · Congress.gov: H.R. 5371 · Timeline 2025-09-30 → ledger ↩↩↩↩↩

  11. FedScoop: OMB must make apportionments website public again · FEDmanager: OMB funding website restored after court rulings · Timeline 2025-03-24 → ledger ↩↩↩↩↩

  12. Reason: $4.9B pocket rescission violates federal law · Timeline 2025-08-29 → ledger ↩↩

  13. CRS R48545 · NBC News: CPB to shut down · Timeline 2025-07-24 → ledger ↩

  14. CNN: Trump administration lays off thousands of federal workers during shutdown · CNBC: Judge blocks Trump from firing federal workers during shutdown · Timeline 2025-10-10 → ledger ↩↩↩↩↩

  15. The Hill: Trump’s move to pay troops during shutdown questioned · Timeline 2025-10-11 → ledger ↩↩↩↩↩↩

  16. NBC: Pentagon accepts anonymous $130 million donation to help pay troops · CNBC: Timothy Mellon is Trump’s $130 million mystery military donor: NYT · Timeline 2025-10-11 → ledger ↩↩↩↩↩

  17. NBC: Federal judge orders Trump administration to pay SNAP benefits out of contingency fund · Timeline 2025-10-31 → ledger ↩↩

  18. NPR: Supreme Court extends pause on SNAP payments · SCOTUSblog: Administration urges Supreme Court to pause SNAP ruling · Timeline 2025-11-07 → ledger ↩↩

  19. NBC News: Partial SNAP benefits for November will be 65%, up from 50% · NCDHHS: Full November SNAP benefits loaded on EBT cards Friday · Timeline 2025-11-07 → ledger ↩↩↩↩↩

  20. House roll call 285 · NBC News: Senators reach tentative deal to end government shutdown (CR to Jan 30; eight Democratic-caucus votes) · NPR: House votes to fund government, ending longest-ever shutdown (222–209) (Wikipedia — underlying reference not retrievable for: 10:24 pm signing time; ~4,000 RIF figure; MilCon-VA and Legislative Branch as the other two full-year bills; December failure of the ACA vote) · Timeline 2025-11-12 → ledger ↩

  21. CNBC: ACA enrollment may fall by 5 million in 2026 (KFF) · Timeline 2025-12-31 → ledger ↩↩↩↩↩

  22. Civil Rights Litigation Clearinghouse: AFGE v. OMB, 3:25-cv-08302 (docket) · Timeline 2025-12-17 → ledger ↩↩↩↩↩

  23. CNN: Judge orders administration to unfreeze more than $16B for NY tunnel · NBC News/Reuters: Tunnel construction to resume after Trump releases funding · Timeline 2026-01 (mid) → ledger ↩↩↩↩↩↩↩↩↩

  24. NYT: Health Dept. rescinds freeze on $10 billion for 5 Democratic states · Timeline 2026-07-13 → ledger ↩↩↩↩

  25. CNN: Administration admits it canceled clean-energy grants in states that voted for Harris · E&E News (Politico): Democrats refer Wright to DOJ over grant comments · Timeline 2026-07-15 → ledger ↩↩↩

  26. AP (via WBUR): Trump is taking longer to approve disaster aid and denying Democratic states more frequently · Politico/E&E News: FEMA said yes to Democratic disaster requests. Trump killed them anyway · Timeline 2026-07 (early) → ledger ↩↩↩↩↩

  27. The Hill: Senate passes stopgap ahead of midterms · NASFAA: House passes CR through Dec 11 · Timeline 2026-09-01 → ledger ↩↩

  28. NASFAA: House passes CR through Dec 11 · LeadingAge: Congress passes funding through Dec 11 · Holland & Knight: Beyond the Midterms: Congress faces converging year-end deadlines (Oct 9) · Gray DC/NewsChannel 10: Congress enters lame-duck session following midterms (Nov 7) · Timeline 2026-09-02 → ledger ↩↩↩↩↩

  29. AP: Trump signs ICE funding through end of term · The Hill: House passes reconciliation ICE funding · Timeline 2026-06-09 → ledger ↩

  30. Ballotpedia News: Trump administration uses pocket rescission power for second time · Timeline 2026-09-30 → ledger ↩↩↩

  31. FedWeek: Administration backs off from using a shutdown as grounds for RIFs · Civil Rights Litigation Clearinghouse: AFGE v. OMB, 3:25-cv-08302 (docket) · Timeline 2026-09-23 → ledger ↩↩↩

  32. Library Journal: Court blocks Trump’s attempt to dismantle IMLS · Timeline 2025-03-14 → ledger ↩↩↩↩

  33. NPR: After a freeze, administration reluctantly agrees to fund EV chargers · Timeline 2025-02-06 → ledger ↩↩↩↩

  34. Federal Register: EO 14154 · Yahoo Finance: Judge unfreezes billions in IRA, IIJA funds · Venable: First Circuit allows broad APA relief against federal funding freeze · Timeline 2025-01-20 → ledger ↩↩↩↩

  35. Supreme Court: Department of State v. AIDS Vaccine Advocacy Coalition, No. 24A831 (Mar 5, 2025) · Roll Call: Supreme Court orders clarity on order unfreezing USAID funds · Timeline 2025-03-05 → ledger ↩↩↩↩↩

  36. Nextgov/FCW: Trump administration knocks out at least 15 oversight websites, saying IGs “lied to the public” · FEDmanager: White House moves to defund key oversight office; websites go dark · Sens. Collins & Grassley: letter to OMB Director Vought on CIGIE/PRAC apportionments (Sep 29 2025, PDF) · Timeline 2025-09-26 → ledger ↩↩↩

  37. NPR: Judge says Education Dept. partisan out-of-office emails violated First Amendment · Education Week: Judge Tells Ed. Dept. to Remove Language Blaming Democrats From Staff Emails · Timeline 2025-11-07 → ledger ↩↩↩↩

  38. Chicago Sun-Times: Federal judge extends order blocking Trump cuts to Illinois public health funding · Becker’s Hospital Review: Federal judge blocks $602M in CDC cuts to 4 states · Just Security: Litigation Tracker (Illinois v. Vought, N.D. Ill. 1:26-cv-01566) · Timeline 2026-02-12 → ledger ↩↩↩↩↩↩

  39. GAO: Department of Energy — Application of the Purpose Statute and Antideficiency Act to agency use of funds under a CR (B-337838) · Timeline 2026-06-04 → ledger ↩↩↩↩↩

  40. Just Security: Litigation Tracker (National Center for Learning Disabilities v. OMB, D. Mass. 1:26-cv-13019) · Timeline 2026-09-17 → ledger ↩↩↩

  41. Cornell LII: 2 U.S.C. ch. 17B, Impoundment Control (§§681–688) legal authority ↩

  42. Cornell LII: 31 U.S.C. §1341, Limitations on expending and obligating amounts · Cornell LII: 31 U.S.C. §1342, Limitation on voluntary services legal authority ↩

  43. GAO: Impoundment Control Act—Withholding of Funds through Their Date of Expiration (B-330330, Dec 10, 2018) legal authority ↩

  44. Cornell LII: 5 U.S.C. ch. 7, Judicial Review (§§701–706) legal authority ↩

  45. Supreme Court: Department of State v. AIDS Vaccine Advocacy Coalition, No. 24A831 (Mar 5, 2025) legal authority ↩

  46. CourtListener: Woonasquatucket River Watershed Council v. Department of Agriculture, No. 1:25-cv-00097 (D.R.I.) (docket) legal authority ↩

  47. Cornell LII: U.S. Constitution, First Amendment legal authority ↩

  48. Cornell LII: U.S. Constitution, Article I, §9, cl. 7 legal authority ↩

  49. Cornell LII: U.S. Constitution, Article I, §8, cl. 1 legal authority ↩↩

  50. Cornell LII: 2 U.S.C. §687, Suits by Comptroller General legal authority ↩↩

  51. GAO: Impoundment Control Act of 1974: Review of the President’s Special Message of August 28, 2025 (B-337805, Sept 12, 2025) legal authority ↩

  52. GAO: Impoundment Control Act of 1974: Review of the President’s Special Message of September 25, 2026 (B-338788) legal authority ↩

  53. Supreme Court: Department of State v. AIDS Vaccine Advocacy Coalition, No. 25A269 (Sept 26, 2025) legal authority ↩

  54. GAO: Department of Energy — Application of the Purpose Statute and Antideficiency Act to Agency Use of Funds under a Continuing Resolution (B-337838, June 4, 2026) legal authority ↩

  55. Cornell LII: 31 U.S.C. §1301, Application legal authority ↩

  56. Cornell LII: U.S. Constitution, Fifth Amendment legal authority ↩

  57. Cornell LII: 42 U.S.C. §5170, Procedure for declaration (Stafford Act §401) legal authority ↩

  58. Cornell LII: 18 U.S.C. §1001, Statements or entries generally legal authority ↩

  59. Civil Rights Litigation Clearinghouse: AFGE v. OMB, No. 3:25-cv-08302 (N.D. Cal.) (docket) legal authority ↩

  60. GovInfo: Public Law 117-169 (Inflation Reduction Act of 2022) legal authority ↩

  61. GovInfo: Public Law 117-58 (Infrastructure Investment and Jobs Act) legal authority ↩

  62. Courthouse News (PDF): AliKhan opinion, Nat’l Council of Nonprofits v. OMB, Doc. 51 (Feb 25, 2025) · NBC News: Judge finds Trump administration violated court order halting funding freeze · Just Security: Litigation Tracker (New York v. Trump, D.R.I.; National Council of Nonprofits v. OMB, D.D.C.) · Yahoo (CNN): The Trump team’s disdain for judicial orders is blowing up in court · Sabin Center: OMB Memo Orders Temporary Pause · Sabin Center: OMB Rescinds Memo · Mayer Brown: Updates and summary of the evolving executive federal funding freeze · FPLG Law: The Preliminary Injunctions Re OMB Memorandum (M-25-13) · Timeline 2025-01-27 → 03-26 → ledger ↩↩↩↩↩↩↩↩

  63. Federal Register: EO 14154 · Yahoo Finance: Judge unfreezes billions in IRA, IIJA funds · Venable: First Circuit allows broad APA relief against federal funding freeze · Just Security: Litigation Tracker · Timeline 2025-01-20 → ledger ↩

  64. NPR · WaPo · Just Security: Litigation Tracker (AVAC v. State; Global Health Council v. Trump) · Timeline 2025-02-25 → ledger ↩↩

  65. CNN: Trump administration lays off thousands of federal workers during shutdown · CNBC: Judge blocks Trump from firing federal workers during shutdown · NBC: Trump signs funding bill, ending record-long government shutdown · FedWeek: Administration backs off from using a shutdown as grounds for RIFs · Civil Rights Litigation Clearinghouse: AFGE v. OMB, 3:25-cv-08302 · KFF: Tracking Key HHS Public Health Policy Actions · Timeline 2025-10-10 → ledger ↩↩

  66. Cornell LII: 5 U.S.C. §7323, Political activity authorized; prohibitions (Hatch Act) legal authority ↩

  67. Government Executive: Watchdog won’t discipline agencies over partisan shutdown posts · Timeline 2026-09-25 → ledger ↩↩↩

  68. CNN: Administration admits it canceled clean-energy grants in states that voted for Harris · NBC News: Administration concedes it canceled research grants in blue states · E&E News (Politico): Democrats refer Wright to DOJ over grant comments · CREW: politicized federal grant decisions violate the Hatch Act · Timeline 2026-07-15 → ledger ↩↩

  69. Cornell LII: 31 U.S.C. §703, Comptroller General and Deputy Comptroller General legal authority ↩↩

  70. Washington Sun: Trump floats Vought deputy to lead GAO · Timeline 2026-10-08 → ledger ↩↩

  71. CNN: judge rebuffs latest attempt to shut down CFPB · American Banker: judge blocks effort to allow CFPB funding to run out · Goodwin (law-firm analysis of the D. Or. ruling): Court vacates CFPB director’s bid to zero out funds · Timeline 2025-12-30 → ledger ↩↩↩↩↩

  72. Consumer Finance Monitor (Ballard Spahr): Federal judge rules CFPB must continue to ask Federal Reserve for funds · Consumer Finance Monitor: CFPB surprisingly appeals Judge Davila’s funding decision to the Ninth Circuit · Timeline 2026-03-13 → ledger ↩↩↩↩↩

  73. PBS/AP: Court blocks new DOT rules targeting immigrant commercial drivers · PBS/AP: Duffy withholds federal funding from New York over immigrant trucker licenses · Governor of New York: Hochul and James sue to restore $73 million in federal highway funds · Timeline 2025-09-26 → ledger ↩↩↩↩↩↩

  74. CBS Minnesota: Minnesota sues Dr. Oz, Robert F. Kennedy Jr. over $243M in deferred Medicaid funding · Star Tribune: Federal judge denies Minnesota’s bid to block Trump administration withholding $243M in Medicaid funds · Timeline 2026-03-02 → ledger ↩↩↩↩↩↩

  75. Cornell LII: 12 U.S.C. § 5497, Funding; penalties and fines — legal authority (text of the provision; § 5497(a)(1) transfers “from the combined earnings of the Federal Reserve System” the amount “reasonably necessary”) ↩

  76. Cornell LII: Pennhurst State School & Hospital v. Halderman, 451 U.S. 1 (1981) legal authority ↩↩

  77. Oregon DOJ federal litigation tracker: California v. Wright (N.D. Cal.) · Timeline 2025-10-01 → ledger ↩↩

  78. CBS News: Judge finds DOGE’s elimination of humanities grants “unlawful” · Timeline 2025-04-01 → ledger ↩↩↩↩↩↩↩↩

  79. NBC New York: Underground Railroad museum sues Trump administration alleging it canceled grant on the basis of race (Mar 21, 2026) · Timeline 2026-03-20 → ledger ↩↩↩↩↩↩

  80. HousingWire: 16 attorneys general sue HUD over fair housing guidance (Mar 17, 2026) · Vermont Attorney General: AG Clark secures full victory in lawsuit challenging attack on fair housing protections (Sept 8, 2026) · Timeline 2026-03-16 → ledger ↩↩↩↩↩↩↩↩

  81. Capital Press: Blue states sue USDA over ‘America first’ grant policy (Mar 23, 2026) · Oregon DOJ: USDA Funding Conditions (Massachusetts v. U.S. Department of Agriculture, D. Mass., 1:26-cv-11396) · Civil Rights Litigation Clearinghouse: Massachusetts v. USDA, 1:26-cv-11396 · Timeline 2026-03-23 → ledger ↩↩↩↩↩↩↩↩

  82. Cornell LII: South Dakota v. Dole, 483 U.S. 203 (1987) legal authority ↩

  83. Cornell LII: Texas Dept. of Housing & Community Affairs v. Inclusive Communities Project, No. 13-1371 (2015) legal authority ↩

  84. Cornell LII: National Federation of Independent Business v. Sebelius, No. 11-393 (2012) legal authority ↩

  85. Just Security: Litigation Tracker (New York v. Trump, D.R.I.; National Council of Nonprofits v. OMB, D.D.C.) · → ledger ↩

  86. Sabin Center: OMB Rescinds Memo · → ledger ↩

  87. Just Security: Litigation Tracker (New York v. Trump, D.R.I.; National Council of Nonprofits v. OMB, D.D.C.) · → ledger ↩

  88. NBC News: Judge finds Trump administration violated court order halting funding freeze · Yahoo (CNN): The Trump team’s disdain for judicial orders is blowing up in court · → ledger ↩

  89. Courthouse News (PDF): AliKhan opinion, Nat’l Council of Nonprofits v. OMB, Doc. 51 (Feb 25, 2025) · → ledger ↩

  90. FPLG Law: The Preliminary Injunctions Re OMB Memorandum (M-25-13) · → ledger ↩

  91. Just Security: Litigation Tracker (New York v. Trump, D.R.I.; National Council of Nonprofits v. OMB, D.D.C.) · → ledger ↩

  92. NPR: Judge orders administration to resume distributing money for EV chargers · → ledger ↩↩↩

  93. NPR: After a freeze, administration reluctantly agrees to fund EV chargers · → ledger ↩↩

  94. Library Journal: Court blocks Trump’s attempt to dismantle IMLS · → ledger ↩↩↩

  95. Library Journal: Court blocks Trump’s attempt to dismantle IMLS · → ledger ↩↩

  96. Library Journal: Court blocks Trump’s attempt to dismantle IMLS · → ledger ↩↩

  97. FedScoop: OMB must make apportionments website public again · → ledger ↩

  98. Reason (Volokh Conspiracy): D.C. Circuit orders Trump administration to restore public database of federal expenditures (Aug 10, 2025) · FEDmanager: OMB funding website restored after court rulings · → ledger ↩

  99. CREW: CREW sues Trump administration for hiding federal spending information from the public · FEDmanager: OMB funding website restored after court rulings · → ledger ↩↩↩

  100. The Art Newspaper: Chair of National Endowment for the Humanities steps down ‘at the direction of President Trump’ (Mar 13, 2025) · → ledger ↩

  101. CBS News: Judge finds DOGE’s elimination of humanities grants “unlawful” · → ledger ↩↩↩↩

  102. Federal News Network: GAO finds second violation of spending law · GAO: Impoundment Control Act decisions · → ledger ↩

  103. GAO: Institute of Museum and Library Services—Applicability of the Impoundment Control Act to Reduction of Agency Functions (B-337375, Jun 16, 2025) · → ledger ↩

  104. GAO: Impoundment Control Act decisions · → ledger ↩

  105. GAO: Impoundment Control Act decisions · → ledger ↩

  106. GAO: Impoundment Control Act decisions · → ledger ↩↩

  107. GAO: Impoundment Control Act decisions · → ledger ↩

  108. GAO: Impoundment Control Act decisions · → ledger ↩

  109. PBS/AP: Court blocks new DOT rules targeting immigrant commercial drivers · → ledger ↩

  110. PBS/AP: Duffy withholds federal funding from New York over immigrant trucker licenses · → ledger ↩

  111. Governor of New York: Hochul and James sue to restore $73 million in federal highway funds · → ledger ↩↩

  112. CNN: Judge orders administration to unfreeze more than $16B for NY tunnel · NBC News/Reuters: Tunnel construction to resume after Trump releases funding · → ledger ↩↩↩↩

  113. NBC News/Reuters: Tunnel construction to resume after Trump releases funding · → ledger ↩↩↩

  114. Just Security: Litigation Tracker (New Jersey v. DOT, S.D.N.Y. 1:26-cv-00939) · → ledger ↩↩↩

  115. ROI-NJ: Trump administration drops appeal to block federal funding for Gateway Tunnel project · → ledger ↩

  116. ROI-NJ: Trump administration drops appeal to block federal funding for Gateway Tunnel project · Mint/Bloomberg: Trump Drops Legal Bid to Block $16 Billion NY-NJ Gateway Tunnel · → ledger ↩↩↩

  117. WaPo: what Democrats want from ICE · → ledger ↩

  118. NBC News: DHS pausing TSA PreCheck and Global Entry; FEMA halts non-disaster responses; ICE/CBP paid from 2025 law (Feb 22) · → ledger ↩

  119. Guardian: Trump signs executive order instructing DHS to immediately pay TSA agents (Mar 27) · → ledger ↩↩↩

  120. Politico: Congress ends record-shattering DHS shutdown · → ledger ↩↩

  121. Consumer Finance Monitor: CFPB surprisingly appeals Judge Davila’s funding decision to the Ninth Circuit · → ledger ↩↩↩

  122. Consumer Finance Monitor (Ballard Spahr): Third District Court Rejects OLC’s Interpretation of CFPB Funding Statute (Sept 30, 2026) · → ledger ↩↩↩

  123. Vermont Attorney General: AG Clark secures full victory in lawsuit challenging attack on fair housing protections (Sept 8, 2026) · → ledger ↩↩

  124. Vermont Attorney General: AG Clark secures full victory in lawsuit challenging attack on fair housing protections (Sept 8, 2026) · → ledger ↩↩

  125. Politico/E&E News: FEMA said yes to Democratic disaster requests. Trump killed them anyway · MS NOW (Maddow Blog): Trump denies disaster aid to four blue states, after approving aid to six red states · → ledger ↩↩↩

  126. Sens. Collins & Grassley: letter to OMB Director Vought on CIGIE/PRAC apportionments (Sep 29 2025, PDF) · Timeline 2025-09-29 → ledger ↩

  127. Nextgov/FCW: Trump administration knocks out at least 15 oversight websites, saying IGs “lied to the public” · FEDmanager: White House moves to defund key oversight office; websites go dark · Timeline 2025-10-01 → ledger ↩↩

  128. Public Citizen: Undoing Accountability · Timeline 2025-11-(mid) → ledger ↩↩↩

  129. CNBC: Judge blocks Trump from firing federal workers during shutdown · Civil Rights Litigation Clearinghouse: AFGE v. OMB, 3:25-cv-08302 · Timeline 2025-10-15 → ledger ↩↩↩

  130. NBC: Trump signs funding bill, ending record-long government shutdown · Timeline 2025-11-12 → ledger ↩↩↩

  131. Civil Rights Litigation Clearinghouse: AFGE v. OMB, 3:25-cv-08302 · Timeline 2025-12-04 → ledger ↩

  132. PBS NewsHour (AP): Here’s what to know about the partial government shutdown and its impact · NBC News: Trump signs bill to end government shutdown and fund DHS for two weeks (Wikipedia — underlying reference not retrievable for: CBP as the agency whose agents killed Pretti; the full list of lapsed departments (Treasury, HHS, HUD, Labor, Education); judicial-warrant demand (WaPo); NPR, PBS and NBC confirm the votes, dates, ID/mask/body-camera demands and the Feb 13 DHS deadline) · Timeline 2026-01-30 → ledger ↩↩

  133. NBC News: Trump signs bill to end government shutdown and fund DHS for two weeks · Timeline 2026-02-03 → ledger ↩↩

  134. Chicago Sun-Times: Federal judge extends order blocking Trump cuts to Illinois public health funding · Just Security: Litigation Tracker (Illinois v. Vought, N.D. Ill. 1:26-cv-01566) · Timeline 2026-03-12 → ledger ↩↩↩↩

  135. Star Tribune: Federal judge denies Minnesota’s bid to block Trump administration withholding $243M in Medicaid funds (search result only, not opened) · Courthouse News: Tostrud order (PDF) (search result only, not opened) · Timeline 2026-04-06 → ledger ↩↩↩↩

  136. AP: Trump signs ICE funding through end of term · CNBC: Trump remarks at Secure America Act signing · Timeline 2026-06-10 → ledger ↩

  137. E&E News (Politico): Democrats refer Wright to DOJ over grant comments · Timeline 2026-08-04 → ledger ↩↩↩↩↩

  138. Roll Call: Trump’s funding cancellation violates budget law, GAO says · GAO: Review of the President’s Special Message of Sep 25, 2026 · Timeline 2026-09-29 → ledger ↩↩↩↩↩↩↩

  139. Just Security: Litigation Tracker (State of Minnesota v. Oz, D. Minn. 0:26-cv-01701) · Timeline 2026-05-07 → ledger ↩↩↩