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 March 28 and April 4, 2025, include:

  • New executive orders and other administrative actions
    • Trade Policy: The administration issued an executive order imposing “reciprocal’ tariffs” and a 10% baseline tariff rate on all imports.
    • Regulatory Policy: DOJ released a memo with reorganization plans that included dissolving its Tax Division.
    • Regulatory Policy: Federal prosecutors moved to dismiss a FCPA case citing the administration’s executive order pausing enforcement.
  • Court decisions
    • DEI: An Illinois federal judge issued a nationwide TRO blocking the DOL from requiring federal grant recipients to certify that they do not operate programs that violate recent executive orders targeting DEI initiatives. (N.D. Ill.)
    • Federal Agencies: A D.C. Circuit panel issued a per curiam order granting an administrative stay of a lower court PI that returned the CFPB to a pause on further cuts to the workforce, contracts, and data. (D.C. Cir.)
    • Federal Agencies: A district court granted a PI and stay sought by states meaning that the federal government must reinstate workers from 20 federal agencies across 19 states and D.C. (D. Md.)
  • New litigations and appeals
    • Trade Policy: The New Civil Liberties Alliance filed a lawsuit challenging the administration’s February and March tariffs on all imports from China, arguing the president does not have authority to impose emergency tariffs without congressional approval. (N.D. Fla.)
    • Federal Agencies: The administration filed an emergency application to stay, pending appeal, a lower court’s PI reinstating 16,000 fired workers at six federal agencies including the Department of the Treasury, after the 9th Circuit denied the request. Respondents, federal employee unions and advocacy groups, argue that the application should be denied and that OPM exceeded its statutory authority. (SCOTUS)

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: DOJ Plan to Dissolve Tax Division

Related Litigation

  • No pending cases at this time.

Trade Policy

Executive Action: Tariffs Against China, Mexico and Canada

Related Litigation

  • Emily Ley Paper Inc v. Trump, No. 25-464 (N.D. Fla.)
  • Challenging the administration’s February and March tariffs on all imports from China, arguing that the president does not have authority to impose emergency tariffs without congressional approval Complaint filed Apr. 3, 2025..

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

  • No pending cases at this time.

Energy and the Environment

Executive Action: Executive Orders Related to Energy

Related Litigation

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

Diversity, Equity and Inclusion

Executive Action: Ending DEI Practices and Policies

Related Litigation

Federal Funding

Executive Action: Federal-Assistance Freeze

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 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
  • State of New York v. Donald J. 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”

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

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

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