(filed February 6, 2025)
U.S. v. State of Illinois, Cook County, City of Chicago - The Trump Administration sued to prohibit the enforcement of several state and local laws, such as Illinois’ Way Forward Act, TRUST Act, Chicago’s Welcoming City Act, and Cook County Ordinance 11-O-73. On July 25, 2025, a federal court dismissed the case with prejudice. Even though one provision of Chicago’s ordinance directly restricted the sharing of citizenship or immigration status information, the court ultimately held that §§1373 and 1644 could not serve as valid preemptive provisions because they regulate state and local governments rather than private actors, relying on Murphy v. NCAA, 584 U.S 453, 477 (2018). The court also rejected the government’s obstacle preemption theory, reasoning that the INA permits state and local cooperation with immigration enforcement but generally does not require it; treating voluntary cooperation as mandatory would conflict with the anti-commandeering doctrine. Also, the court rejected the government’s argument that the policies unlawfully discriminated against or directly regulated the federal government. Lastly, the court held the government lacked standing against the individually named officials because it had not adequately tied its alleged injuries to those officials. On October 27, 2025, the government appealed the decision to the Seventh Circuit Court of Appeals (No. 25-2904).