In welcome news for the Institute of Museum and Library Services and two more federal agencies targeted for dismantling by a presidential executive order, the District Court of Rhode Island has granted 21 states’ attorneys general the preliminary injunction they sought in Rhode Island v. Trump. In response to the evidence and to an April 18 motion hearing, chief judge John J. McConnell Jr. granted the states’ motion, agreeing with the plaintiffs that the executive order violates the Administrative Procedures Act, separation of powers principle, and the Take Care clause of the U.S. Constitution.

From the first paragraph of his order, Judge McConnell upheld that Congress controls the agencies and appropriates funding, and he referred to “the arbitrary and capricious way” the March 14 order was implemented at the IMLS, Minority Business Development Agency (MBDA), and Federal Mediation and Conciliation Service (FMCS). He determined that the EO “disregards the fundamental constitutional role of each of the branches of our federal government; specifically, it ignores the unshakable principles that Congress makes the law and appropriates funds, and the Executive implements the law Congress enacted and spends the funds Congress appropriated.”

Notably, the order’s timing closely coincided with FY25 congressional appropriations. On March 15, the day after issuing the EO, President Donald Trump—a named defendant in the case—approved the Full-Year Continuing Appropriations and Extensions Act, mandating FY2024-level funding for IMLS and other agencies through September 25, 2025. In 2024, IMLS was appropriated $294,800,000, so the same amount was approved for FY25.

In some cases, IMLS is issuing checks, fulfilling its statutory obligations; several U.S. states report receiving their Grants to States reimbursements for FY24 and FY25 in recent weeks. There are three significant exceptions: California, Connecticut, and Washington received word April 3 that their Grants to States had been slashed for 2025. Judge McConnell acknowledged that the EO indeed calls for “the non-statutory components and functions” of the agencies to be eliminated, yet he observed that “the Defendants have not shown that any analysis was conducted to determine which ‘components and functions’ of IMLS, MBDA, and FMCS are statutorily required, and which are not.”

Overall, the judge found, the defendants’ “justifications for eliminating programs, terminating grants, and implementing large-scale employee RIFs have been couched in mere conclusory statements,” citing the March 14 order without providing any rationale. For this reason, he said, the plaintiffs had a strong likelihood of success for their claims that the actions were capricious.

The unrefuted record

In making his decision, Judge McConnell also outlined the strong evidence of how severe cutbacks have hobbled IMLS, MBDA, and FMCS. All three agencies have furloughed most employees—“the unrebutted record reveals that MBDA’s workforce has been reduced to zero”—and IMLS has terminated more than 1,000 grants with a boilerplate letter that declares projects “no longer consistent with the agency’s priorities.” IMLS, for instance, can no longer award and process Grants to States or competitive grants, nor conduct its Public Library Survey, with a staff of 12 and without its shuttered Office of Research and Evaluation.

The defendants claimed that any irreparable harm caused by such changes was speculative or could be remedied by economic redress at a later date. On this matter, the judge wrote, “The unrefuted record before the Court reveals that the States are relying on more than mere speculation when asserting to harms—current or imminent—stemming from the Defendants’ efforts to significantly reduce agency services and personnel under the Reduction EO.”

Among examples from all three agencies, Judge McConnell found that state libraries “have attested to being compelled to cut staff and shut down programs due to the grant terminations and missed grant payments in the wake of the agency’s apparent implementation of the Reduction EO.” He further clarified that neither party was saying that states had breached the terms of their grant agreements. Instead, the questions were whether defendants “exceeded the bounds of their statutory or constitutional authority,” and whether grantees are “presently entitled to” the awards they were promised. Here, the judge sided with the plaintiffs.

Judge McConnell added that, “because of the finding of likelihood of success by the States and the large-scale irreparable harm that would occur without the preliminary injunction, the Court denies the Defendants’ request to stay this Order for seven days.”

One plaintiff in the suit is the state of Maine, where loss of IMLS funding led to layoffs of 13 people and the temporary closure of public libraries in April. Over the May 3 weekend, Maine state librarian Lori Fisher notified library supporters that the state had received about half of its FY25 IMLS funding, allowing three people to be brought back on staff and two to be reallocated to position vacancies. The eight remaining library workers are to be let go May 8, although Fisher said “layoffs could be rescinded if federal funding is restored in full. We are awaiting guidance from IMLS on the status of our 50% remaining allocation” for FY25. Fisher called it “a traumatic time” for Maine libraries’ leadership and staff.

FY26 and the battle ahead

The 49-page decision comes hot on the heels of a partial, temporary restraining order (TRO) granted May 1 in ALA v. Sonderling, filed in the District Court of the District of Columbia by the American Library Association and the American Federation of State, County, and Municipal Employees, AFL-CIO (AFSCME) against IMLS acting director Keith Sonderling et al. The TRO averted a reduction in force scheduled for May 4; IMLS HR informed employees on May 2 that their paid administrative leave would continue.

Plaintiffs and defendants in that case filed a joint status update May 6, with ALA and AFSCME requesting an extension of the TRO "until the Court issues a ruling on the preliminary injunction or the case is otherwise resolved." They also wish to file a short brief with supplemental information by May 15. Later the same day, the defendants filed a separate motion for reconsideration of the D.C. court's memorandum and TRO.

Judge McConnell’s ruling in Rhode Island also arrives just days after the Trump administration released its FY2026 federal budget proposal May 2, seeking to defund IMLS altogether. In previous years, bipartisan support of libraries in Congress has sustained IMLS, and ALA is currently urging members and allies to participate in its #FundLibraries campaign, urging representatives to throw their weight behind libraries.

John Chrastka, executive director of the advocacy organization EveryLibrary, said that library supporters must lobby hard at the national and state levels, appealing to Congress and to state legislatures and governors. “If federal support collapses, the burden of sustaining essential library services, particularly those managed by state library agencies, will shift almost entirely to state governments,” he said. “These elected officials need to hear from us now so they are informed, engaged, and prepared to step up."

This story has been updated with developing information.