Executive Orders and Actions Impacting Cities

HSTFs are to be established by the U.S. Attorney General and Secretary of Homeland Security and include representation from other federal agencies with law enforcement officers, or agencies with the ability to provide logistics, intelligence, and operational support. In addition, HSTFs are to include representation from relevant state and local law enforcement agencies.

As stated in President Trump’s order (Protecting the American People Against Invasion), the objective of each HSTF is to “end the presence of criminal cartels, foreign gangs, and transnational criminal organizations throughout the United States, dismantle cross-border human smuggling and trafficking networks, end the scourge of human smuggling and trafficking, with a particular focus on such offenses involving children, and ensure the use of all available law enforcement tools to faithfully execute the immigration laws of the United States.”

Yes, law enforcement members of LMCIT’s PATROL — Peace officer Accredited TRaining OnLine program, can learn about immigration law and their responsibilities as an officer. This course was updated in April 2025. Read more about the PATROL program.

There is no specific statutory definition of sanctuary city. The United States Attorney General describes them to include “state or local jurisdictions that refuse to comply with 8 U.S.C. § 1373, refuse to certify compliance with § 1373, or willfully fail to comply with other applicable federal immigration laws.” Sanctuary cities generally limit their cooperation with federal immigration officials by adopting ordinances or policies that limit the use of city resources available to aid immigration officials in investigating federal immigration violations. Regardless, local law enforcement agencies still enforce state and local criminal laws.

In an April 28, 2025, Executive Order, Protecting American Communities From Criminal Aliens, the Attorney General, in coordination with the Secretary of Homeland Security, was directed to publish a list of states and local jurisdictions that obstruct the enforcement of federal immigration laws (sanctuary jurisdictions). Those jurisdictions will be notified and provided an opportunity to correct any concerns.

The League does not track this data.

The Minnesota Attorney General has issued an opinion determining that Minnesota Statutes, section 629.30 and Minnesota Statutes, section 629.34 prohibit state and local law enforcement agencies from holding someone based on an immigration detainer if the person would otherwise be released from custody.

Cities are encouraged to work with their city attorneys to understand the nature of immigration detainers and what rights those orders grant federal officials.

City leadership, in consultation with the city attorney, should provide guidance to city staff on how to respond to such requests.

In April 2025, a judge in Wisconsin was arrested and charged in federal court for allegedly helping an undocumented immigrant avoid arrest in the Milwaukee County Courthouse. City leaders, in consultation with your city attorney, should provide guidance to city staff on how to respond to requests from immigration officials in a manner that protects the rights of all parties.

The executive order does not require cities to discontinue current DEI programs. However, cities should stay tuned to determine what, if any, effect DEI programs will have on federal grants and assistance. In addition, President Trump’s order requires the creation of a report, within 120 days of the order, containing recommendations for enforcing federal civil rights laws and taking other appropriate measures to encourage the “private sector to end illegal discrimination and preferences, including DEI.” It is unclear what, if any, affect this report will have on cities. It is always important to work with your city attorney if review or revision to an individual city’s program is being contemplated.

The League does not track this data.

The U.S. Equal Employment Opportunity Commission (EEOC) has provided guidance entitled What You Should Know About DEI-Related Discrimination at Work. City staff, in consultation with the city attorney, should review this guidance and determine if changes need to be made to any DEI policies or programs.

There is no prohibition on mandatory DEI training. However, the U.S. Equal Employment Opportunity Commission’s (EEOC) guidance, What You Should Know About DEI-Related Discrimination at Work, states that DEI training might create a hostile work environment. Whether a particular training is deemed a violation of Title VII will depend on the content of the training.

The U.S. Equal Employment Opportunity Commission (EEOC) sent letters to several law firms asking for information on such employee groups such as “Asian Pacific Islander Resource Group” and “Black Business Professionals Affinity Group.” If a city sponsors or facilitates these types of groups, it is advisable to ensure that participation is optional and open to others regardless of protected characteristics. Read more about the letters the EEOC sent to the law firms.

Generally, the executive orders do not apply to local policies. However, cities should review any federal grants and assistance they receive to determine if local policies and procedures will jeopardize those funds. It is always important to work with your city attorney if review or revision to an individual city’s policies or procedures is being contemplated.

In addition, in the Executive Order, Strengthing and Unleashing America’s Law Enforcement to Pursue Criminals and Protect Innocent Citizens, President Trump directs the Attorney General to prioritize prosecution of local officials who:

• Direct the obstruction of criminal law, including “prohibiting law enforcement officers from carrying out duties necessary for public safety,” and
• Engage in discrimination or civil-rights violations “under the guise of ‘diversity, equity, and inclusion’ initiatives that restrict law enforcement activity ….”

It is unclear what types of programs or policies the administration will be reviewing pursuant to this order.

The Federal Student Aid Office is reviewing the recent executive orders regarding the PSLF. Currently, there are no changes to PSLF.

There is no definitive list of grants or programs that have been eliminated due to executive orders. However, several lawsuits have been filed challenging specific programs including:

• Department of Health and Human Services eliminating more than $11 billion to local governments (pdf) to address the effects of the pandemic as well as COVID-related grant programs. Harris County et al v. Kennedy Jr. et al.
• AmeriCorp grants. San Franscisco Unified School District v. AmeriCorps.
• Inflation Reduction Act and Infrastructure Investment and Jobs Act. The Sustainability Institute v. Trump.

Yes. Almost immediately, many stakeholders turned to the courts to seek clarity. On Jan. 28, 2025, a federal judge temporarily blocked the federal funding pause from going into effect until Feb. 3, 2025. It is anticipated there will be many legal challenges for the federal courts to consider in the coming days and weeks. In addition, a coalition of 23 state attorneys general, including Minnesota’s, filed a lawsuit in a Rhode Island court seeking to stop the implementation of any funding pauses authorized by the executive orders.

On Jan. 31, the Federal District Court of Rhode Island issued a temporary restraining order against the federal government. The Court’s order noted that the federal government “shall not pause, freeze, impede, block, cancel, or terminate its compliance with award and obligations to provide federal financial assistance to the States, and … shall not impede the States’ access to such awards and obligations, except based on the applicable authorizing statutes, regulations and terms.”

A preliminary injunction was granted on March 6, 2025, prohibiting the federal government from “pausing, freezing, blocking, canceling, suspending, terminating, or otherwise impeding the disbursement of appropriated federal funds to the States … ”

The federal government’s motion to stay the preliminary injunction was denied on March 27, 2025. Numerous additional lawsuits have been filed across the country challenging aspects of the executive orders and are being tracked by LMC.

The funding pause may cause delays or cancellations of projects and may result in economic uncertainty, and impact both future and local projects already underway. Cities should carefully review their grant agreements for payment obligations. Cities that havenʼt signed grant agreements should reach out to the relevant agencies and expect that responses will vary by program. For new contracts that are contingent upon the cityʼs receipt of anticipated federal funding, cities should consider including a provision that if such funding is not received, is reduced, or is otherwise unavailable because of any action or decision made by an agency providing funding the city may, upon written notice to the other party, suspend performance of or terminate the contract, in whole or in part, without liability or penalty.

Legal challenges both for project delays and the broader constitutional implications should be expected. And finally, cities should inform their agency contacts about any disruptions, and document the related costs or losses (and share this with LMC and your members of Congress).

Through a memo released by the Secretary of the U.S. Department of Transportation (DOT), DOT staff is directed to identify and eliminate all orders, directives, rules, regulations, notices, guidance documents, funding agreements, programs and policy statements, or portion thereof, adopted during President Biden’s term which reference or relate in any way to climate change, “greenhouse gas” emissions, racial equity, gender identity, “diversity, equity, and inclusion” goals, environmental justice, or the Justice 40 Initiative. It is unclear what, if any, affect this memo will have on ongoing funding agreements with DOT. 

In addition, the DOT Secretary issued an order to ensure that all DOT grants, loans, contracts and DOT-supported or assisted state contracts meet specific requirements.  Among other requirements, the DOT Secretary’s order provides that DOT programs, including grants, loan and contracts, shall not be used to “further local political objectives or for projects and goals that are purely local in nature and unrelated to a proper Federal interest.”

The order provides that DOT programs, including loans, grants, and contracts shall prioritize projects and goals that:

• Utilize user-pay models.
• Direct funding to local opportunity zones.
• To the extent practicable, mitigate the unique impacts of DOT activities on families and family-specific difficulties, such as the accessibility of transportation to families with young children and give preference to communities with marriage and birth rates higher than the national average.
• Prohibit recipients of DOT funds from imposing vaccine and mask mandates.
• Require local compliance or cooperation with federal immigration enforcement and with other presidential goals.

Until further guidance is given by DOT, it remains unclear how these changes will affect existing city projects. 

It is common for cities to receive funds from state programs which are funded by the federal government. Cities should check with the state to determine if any of these programs are affected.

The executive order, Council to Assess the Federal Emergency Management Agency, does not require any immediate changes to FEMA responses. The order creates a “FEMA Review Council” charged with assessing and enhancing FEMA’s effectiveness. The review council is to provide an assessment of the adequacy of FEMA’s response to disasters during the previous four years, and compare FEMA’s responses with other state, local, and private sector responses. It is not yet known if any of the council’s recommendations will affect cities. However, the State of New York has filed a lawsuit challenging the federal government’s actions freezing certain FEMA funds.

A recent memo issued by FEMA recommends restricting FEMA funds to sanctuary cities (pdf). However, the limits are not to apply to disaster grants.

Cities should carefully review any grant conditions from the federal government to ensure they are able to meet them. Federal agencies have recently modified their grant conditions to include new terms. 

For example, the Department of Homeland Security’s Standard Terms and Conditions for financial assistance now include requirements that recipients must assist immigration officials and refrain from operating any programs that advance or promote DEI. Similar requirements have been found in grants from the Federal Aviation Administration, Housing and Urban Development, and Department of Transportation.

Yes. Online portals for reimbursement of existing federal grant awards have sometimes been unavailable when users attempt to access them. There is generally no warning of this unavailability or notice when the portal will reopen. Minnesota Management and Budget (MMB) suggests that cities regularly check the portals and submit reimbursement requests as soon as eligible.

Yes, Minnesota Management and Budget (MMB) is tracking when the state receives notification that there is a temporary disruption or a permanent cancellation of funds the state was expecting. MMB updates this resource weekdays around 4 p.m. View the MMB federal funding disruptions tracker. 

It is possible that suppliers will attempt to raise prices of goods due to tariffs issued by the Trump Administration. Whether these costs can be passed through to a city will depend on the terms of the existing contract. Cities should review current contracts to determine if suppliers are allowed to charge a city more for goods affected by the tariffs.

View the White House webpage for more information about the executive actions.

This is a complex and rapidly evolving situation. There are still many uncertainties, and we are working diligently to gather more information. While we are striving to stay nimble and responsive to your needs, we want to ensure that neither we nor you take premature actions before having the clarity and context required to make informed decisions. We also encourage you to work closely with your city attorney as your city develops plans related to executive orders and other federal actions.

If you have questions related to these FAQs or the federal executive orders in general, contact the League’s Research Department at [email protected].