Brief of 157 Members of Congress as Amici Curiae — New York v. Trump (1st Cir.)

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A brief for 157 members of Congress as amici curiae in support of the appellees and affirmance, filed July 25, 2025 in the U.S. Court of Appeals for the First Circuit, Nos. 25-1236 and 25-1413, on appeal from the U.S. District Court for the District of Rhode Island, Case No. 1:25-CV-00039-JJM. The brief argues that the President may not unilaterally withhold funds based on his own priorities or policy preferences, and that Congress has the exclusive power to appropriate funds and to make laws governing their use. It argues that the executive orders required a funding freeze based on a misconception of presidential power, and that the failure to carry out the law harms the constituents of the amici and the legislative process. The brief is 44 pages and closes with an appendix listing each member of Congress joining it.

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Nos. 25-1236, 25-1413 
IN THE UNITED STATES COURT OF APPEALS 
FOR THE FIRST CIRCUIT 
 
STATE OF NEW YORK; STATE OF CALIFORNIA; STATE OF 
ILLINOIS; STATE OF RHODE ISLAND; STATE OF NEW JERSEY; 
COMMONWEALTH OF MASSACHUSETTS; STATE OF ARIZONA; 
STATE OF COLORADO; STATE OF CONNECTICUT; STATE OF 
DELAWARE; DISTRICT OF COLUMBIA; STATE OF HAWAII; STATE 
OF MAINE; STATE OF MARYLAND; STATE OF MICHIGAN; STATE 
OF MINNESOTA; STATE OF NEVADA; STATE OF NORTH 
CAROLINA; STATE OF NEW MEXICO; STATE OF OREGON; STATE 
OF VERMONT; STATE OF WASHINGTON; STATE OF WISCONSIN, 
OFFICE OF THE GOVERNOR OF KENTUCKY, ex rel. ANDREW 
BESHEAR, in their official capacity as Governor of the Commonwealth 
of Kentucky, 
Plaintiffs-Appellees, 
(caption continued on inside cover) 
 
 
On Appeal from the United States District Court 
for the District of Rhode Island 
The Honorable John J. McConnell, Jr., District Judge 
Case No. 1:25-CV-00039-JJM 
 
 
BRIEF FOR 157 MEMBERS OF CONGRESS  
AS AMICI CURIAE  
IN SUPPORT OF APPELLEES AND AFFIRMANCE 
 
 
Maura Eileen O’Connor 
THE BRENNAN CENTER FOR JUSTICE 
AT NYU SCHOOL OF LAW 
1140 Connecticut Ave., NW 
11th Floor, Suite 1150 
Washington, DC 20036 
Telephone: (202) 249-7190 
Brian A. Sutherland 
Melanie C. Gold 
COMPLEX APPELLATE  
LITIGATION GROUP LLP 
96 Jessie Street 
San Francisco, CA 94105 
Telephone: (415) 649-6700 
 
Attorneys for Amici Curiae 
 

 
v. 
DONALD J. TRUMP, in their official capacity as President of the 
United States; U.S. OFFICE OF MANAGEMENT AND BUDGET; 
RUSSELL THURLOW VOUGHT, in their official capacity as Director 
of the U.S. Office of Management and Budget; U.S. DEPARTMENT OF 
THE TREASURY; SCOTT BESSENT, in their official capacity as 
Secretary of the Treasury; PATRICIA COLLINS, in their official 
capacity as Treasurer of the U.S.; U.S. DEPARTMENT OF HEALTH 
AND HUMAN SERVICES; ROBERT F. KENNEDY, JR., in their 
official capacity as Secretary of the Department of Health and Human 
Services; U.S. DEPARTMENT OF EDUCATION; LINDA MCMAHON, 
in their official capacity as Secretary of Education; U.S. FEDERAL 
EMERGENCY MANAGEMENT AGENCY; CAMERON HAMILTON, in 
their official capacity as Acting Administrator of the U.S. Federal 
Emergency Management Agency; U.S. DEPARTMENT OF 
TRANSPORTATION; SEAN P. DUFFY, in their official capacity as 
Secretary of Transportation; U.S. DEPARTMENT OF LABOR; LORI 
CHAVEZ-DEREMER, in their official capacity as Secretary of Labor; 
U.S. DEPARTMENT OF ENERGY; CHRISTOPHER ALLEN WRIGHT, 
in their official capacity as Secretary of the U.S. Department of Energy; 
U.S. ENVIRONMENTAL PROTECTION AGENCY; LEE M. ZELDIN, 
in their official capacity as Administrator of the U.S. Environmental 
Protection Agency; U.S. DEPARTMENT OF THE INTERIOR ; 
DOUGLAS BURGUM, in their official capacity as Secretary of the 
Interior; U.S. DEPARTMENT OF HOMELAND SECURITY; KRISTI 
NOEM, in their official capacity as Secretary of the U.S. Department of 
Homeland Security; U.S. DEPARTMENT OF JUSTICE; PAMELA J. 
BONDI, in their official capacity as Attorney General; NATIONAL 
SCIENCE FOUNDATION; DR. SETHURAMAN PANCHANATHAN, in 
their official capacity as Director of the National Science Foundation; 
U.S. DEPARTMENT OF AGRICULTURE; BROOKE ROLLINS, in 
their official capacity as Secretary of Agriculture; U.S. DEPARTMENT 
OF HOUSING & URBAN DEVELOPMENT; SCOTT TURNER, in their 
official capacity as Secretary of Housing and Urban Development; U.S. 
DEPARTMENT OF STATE; MARCO RUBIO, in their official capacities 
as Secretary of State and Acting Administrator of the United States 
Agency for International Development; US AGENCY FOR 
INTERNATIONAL DEVELOPMENT; U.S. DEPARTMENT OF 
DEFENSE; PETE HEGSETH, in their official capacity as Secretary of 
Defense; U.S. DEPARTMENT OF VETERANS AFFAIRS; DOUGLAS 
COLLINS, in their official capacity as Secretary of Veterans Affairs; 

 
U.S. DEPARTMENT OF COMMERCE; HOWARD LUTNICK, in their 
official capacity as Secretary of Commerce; NATIONAL 
AERONAUTICS AND SPACE ADMINISTRATION; JANET PETRO, in 
their official capacity as Acting Administrator of National Aeronautics 
and Space Administration; CORPORATION FOR NATIONAL AND 
COMMUNITY SERVICE; JENNIFER BASTRESS TAHMASEBI, in 
their official capacity as Interim Head of the Corporation for National 
and Community Service; U.S. SOCIAL SECURITY 
ADMINISTRATION; LELAND DUDEK, in their official capacity as 
Acting Commissioner of United States Social Security Administration; 
U.S. SMALL BUSINESS ADMINISTRATION; KELLY LOEFFLER, in 
their official capacity as Acting Administrator of U.S. Small 
Business Administration, 
Defendants-Appellants. 

i 
CORPORATE DISCLOSURE STATEMENT 
Pursuant to Federal Rules of Appellate Procedure 26.1 and 29, no 
amici curiae is a nongovernmental corporation. 
 

ii 
TABLE OF CONTENTS 
Page 
CORPORATE DISCLOSURE STATEMENT............................................. i
INTERESTS OF AMICI CURIAE ............................................................. 1
SUMMARY OF ARGUMENT .................................................................... 2
ARGUMENT ............................................................................................... 4
I.
The President may not unilaterally withhold funds based on
his own priorities or policy preferences. ........................................... 4
A.
Congress has the exclusive power to appropriate funds
and to make laws governing their use. ................................... 4
B.
The executive orders required a funding freeze based
on a misconception of presidential power. .............................. 7
II.
The President’s failure to carry out the law harms the
constituents of amici and Congress itself. ..................................... 10
A.
The funding freeze harms people. ......................................... 10
B.
The funding freeze harms the legislative process. ............... 15
CONCLUSION ......................................................................................... 21
CERTIFICATE OF COMPLIANCE
CERTIFICATE OF SERVICE
APPENDIX: LIST OF AMICI CURIAE

iii 
TABLE OF AUTHORITIES 
Cases 
Climate United Fund v. Citibank, N.A.,  
No. 25-cv-698, 2025 WL 1131412 (D.D.C. Apr. 16, 2025) ................... 12 
Clinton v. City of New York,  
524 U.S. 417 (1998) ............................................................................. 5, 6 
Consumer Fin. Prot. Bureau v.  
Cmty. Fin. Servs. Ass’n of Am., Ltd.,  
601 U.S. 416 (2024) ................................................................................. 7 
Consumer Prod. Safety Comm’n v. GTE Sylvania, Inc.,  
447 U.S. 102 (1980) ................................................................................. 7 
Elev8 Balt., Inc. v. Corp. for Nat’l & Cmty. Serv.,  
Civ. No. MJM-25-1458, 2025 WL 1865971 
(D. Md. July 7, 2025) ............................................................................. 11 
In re Aiken County,  
725 F.3d 255 (D.C. Cir. 2013) ................................................................. 6 
INS v. Chadha,  
462 U.S. 919 (1983) ....................................................................... 5, 6, 10 
James v. United States,  
366 U.S. 213 (1961) ................................................................................. 7 
Maryland v. Corp. for Nat’l & Cmty. Serv.,  
Civ. No. DLB-25-1363, 2025 WL 1585051 
(D. Md. June 5, 2025) ............................................................................ 11 
Mistretta v. United States,  
488 U.S. 361 (1989) ................................................................................. 4 
NCAA v. Alston,  
594 U.S. 69 (2021) ................................................................................... 7 

 
 
TABLE OF AUTHORITIES 
(continued) 
Page 
 
iv 
New York v. Trump,  
133 F.4th 51 (1st Cir. 2025) .................................................................... 8 
New York v. Trump,  
769 F. Supp. 3d 119 (D.R.I. 2025) ........................................................ 13 
New York v. Trump,  
C.A. No. 25-cv-39, 2025 WL 1009025 (D.R.I. Apr. 4, 2025) ................ 12 
Sustainability Inst. v. Trump,  
No. 25-cv-2152, 2025 WL 1486979 (D.S.C. May 20, 2025) .................. 13 
Thakur v. Trump,  
No. 25-cv-04737, 2025 WL 1734471 (N.D. Cal. June 23, 2025) .......... 12 
U.S. Dep’t of Navy v. Fed. Lab. Rels. Auth.,  
665 F.3d 1339 (D.C. Cir. 2012) ............................................................... 5 
United States v. Munoz-Flores,  
495 U.S. 385 (1990) ................................................................................. 9 
Washington v. U.S. Dep’t of Transp.,  
No. 25-cv-00848, 2025 WL 1742893 
(W.D. Wash. June 24, 2025) ................................................................. 13 
Woonasquatucket River Watershed Council v. USDA,  
No. 25-cv-00097, 2025 WL 1116157 (D.R.I. Apr. 15, 2025) ................. 13 
Youngstown Sheet & Tube Co. v. Sawyer,  
343 U.S. 579 (1952) ................................................................................. 4 
 
 
 

 
 
TABLE OF AUTHORITIES 
(continued) 
Page 
 
v 
Constitutional Provisions 
U.S. Const. art. I, § 2 .................................................................................. 9 
U.S. Const. art. I, § 3 .................................................................................. 9 
U.S. Const. art. I, § 8, cl. 1 ......................................................................... 4 
U.S. Const. art. II, § 3 ............................................................................. 6, 9 
U.S. Const. amend. XVII ............................................................................ 9 
Statutes 
2 U.S.C. § 622 ............................................................................................. 5 
2 U.S.C. § 631 ........................................................................................... 16 
2 U.S.C. § 681 ........................................................................................... 18 
2 U.S.C. § 683 ........................................................................................... 19 
2 U.S.C. § 684 ........................................................................................... 19 
2 U.S.C. § 685 ........................................................................................... 19 
31 U.S.C. § 703.......................................................................................... 19 
31 U.S.C. § 1301.......................................................................................... 5 
General Appropriation Act, 1951,  
ch. 896, 64 Stat. 595 (1950) .................................................................. 18 
Impoundment Control Act of 1974, 
Pub. L. No. 93-344, tit. X, 88 Stat. 297 ........................................ passim 

 
 
TABLE OF AUTHORITIES 
(continued) 
Page 
 
vi 
Other Authorities 
Appropriations Comm. Democrats, Trump’s Unprecedented 
Funding Freeze Hits Communities Across America, 
https://democrats-appropriations.house.gov/trumps-
unprecedented-funding-freeze-hits-communities-across-
america (last visited July 25, 2025) ............................................... 10, 11 
Claire Brown, E.P.A. Offers No New Evidence in Battle over $20 
Billion in Climate Grants, N.Y. Times (Mar. 17, 2025) ...................... 12 
Congressional Research Service, R42388, The Congressional 
Appropriations Process: An Introduction (2016) .................................. 16 
Congressional Research Service, R44124, Appropriations Report 
Language: Overview of Development and Components (2023) ............ 16 
Congressional Research Service, RS20268, Agency Justification 
of the President’s Budget (2008) ........................................................... 16 
Michael A. DiNapoli Jr. et al., States Face Uncertainty as an 
Estimated $6.2 Billion in K-12 Funding Remains Unreleased: 
Here’s the Fiscal Impact by State, Learning Pol’y Inst.  
(June 30, 2025) ...................................................................................... 11 
Maggie Dresser, Federal Funding Freezes Have Chilling Effect 
on Rural Domestic Violence Resources, Flathead Beacon  
(Apr. 30, 2025) ....................................................................................... 12 
The Federalist No. 47 ................................................................................. 5 
The Federalist No. 51 ................................................................................. 5 
The Federalist No. 58 ................................................................................. 9 
H.R. Rep. No. 118-966 (2025) ................................................................... 15 

 
 
TABLE OF AUTHORITIES 
(continued) 
Page 
 
vii 
Impoundment Control Act–Withholding of Funds Through 
Their Date of Expiration, B-330330,  
2018 WL 6445752 (Comp. Gen. Dec. 10, 2018) .................................... 19 
Cheyanne Mumphrey, Head Start Funding Lags by Nearly $1 
Billion This Year, Causing Some Preschool Closures,  
AP (Apr. 16, 2025) ................................................................................. 14 
Note, Impoundment of Funds,  
86 Harv. L. Rev. 1505 (1973) ................................................................ 18 
OMB, Exec. Off. of the President, Circular No. A-11, 
Preparation, Submission, and Execution of the Budget  
(July 2024) ............................................................................................. 16 
OMB, Exec. Off. of the President, Memorandum M-25-13  
(Jan. 27, 2025) ......................................................................................... 8 
OMB–Withholding of Ukraine Security Assistance, B-331564,  
2020 WL 241373 (Comp. Gen. Jan. 16, 2020) ................................ 5, 6, 9 
Linda Qiu et al., Trump’s Funding Freezes Bruise a Core 
Constituency: Farmers, N.Y. Times (Feb. 13, 2025) ............................ 11 
Morgan Rothborne, Lomakatsi: Fed Funds Freeze Means 
Employee Layoffs, Fewer Prescribed Burns, Ashland.news 
(Mar. 7, 2025) ........................................................................................ 11 
Selena Simmons-Duffin, ‘Where’s Our Money?’ CDC Grant 
Funding Is Moving So Slowly Layoffs Are Happening, NPR 
(June 28, 2025) ...................................................................................... 14 
U.S. Department of Transportation, Federal Highway 
Administration–Application of the Impoundment Control Act 
to Memorandum Suspending Approval of State Electric 
Vehicle Infrastructure Deployment Plans, B-337137,  
2025 WL 1521234 (Comp. Gen. May 22, 2025) .................................... 13 

 
 
TABLE OF AUTHORITIES 
(continued) 
Page 
 
viii 
U.S. Gov’t Accountability Off., GAO-16-464SP,  
Principles of Federal Appropriations Law (4th ed. 2016) ..................... 5 
Bianca Vázquez Toness, More Than 20 States Sue Trump 
Administration over Frozen After-School and Summer 
Funding, AP (July 14, 2025) ................................................................. 11 
Chloe Veltman, Sweeping Cuts Hit NEA After Trump 
Administration Calls to Eliminate the Agency,  
NPR (May 5, 2025) ................................................................................ 13 
Sara Wilson, Memorandum for All DOE Funding Agreements or 
Awards (Jan. 27, 2025) ......................................................................... 13 
 
 

 
1 
INTERESTS OF AMICI CURIAE 
Amici curiae listed in the attached appendix are members of 
Congress. They are interested in this case because they took an oath to 
uphold and defend the Constitution, and here, the President is 
attempting to override Congress’s constitutional lawmaking authority. 
They are interested because they represent people who are irreparably 
harmed by the President’s unlawful funding freeze. They are interested 
because the funding freeze harms Congress itself.  
Congress depends on the predictable execution of the laws it 
writes. And it has enacted laws to ensure that it receives information it 
needs to appropriate funds effectively. The failure of the President and 
the Office of Management and Budget (OMB) to carry out the 
appropriations laws and to provide required information frustrates 
Congress’s ability to legislate for the future.  
With this brief, amici aim to assist the Court by explaining why 
the funding freeze is unlawful and harmful from the unique perspective 
of current members of Congress. All parties have consented to the filing 
of this brief. No person, other than amici curiae and their counsel, 
authored this brief in whole or in part or contributed funds intended to 
fund the preparing or submitting of this brief.  

 
2 
SUMMARY OF ARGUMENT 
Appropriations are laws. The President must take care to ensure 
that appropriations laws are faithfully executed, just like any other law. 
If a President wishes to change a law, including an appropriations law, 
the President must address that request to Congress. When a new 
President is elected, the laws of the United States are not wiped clean, 
and a new President may not overturn whatever laws they wish. 
Rather, for our system of government to function, the laws must be 
followed, and must have stable meaning across administrations, unless 
and until they are changed by Congress or enjoined by a court. 
President Trump and OMB have acted to defeat the purpose of the 
appropriations laws in a manner that is both arbitrary and contrary to 
law. Through their orders and actions, they have unilaterally acted 
under the presumption that federal funding can be broadly frozen by 
fiat, in some cases indefinitely, until courts say otherwise. Their 
presumption is exactly backwards. The executive branch cannot freeze 
funding by fiat—that is, refuse to carry out appropriations made by law. 
If it wishes to defer the obligation or expenditure of any lawfully 
enacted appropriation, the executive branch must identify the statutory 
authority that allows such actions, and follow the conditions, 
procedures, and terms laid out by that provision of law and the 

 
3 
Impoundment Control Act of 1974. To allow the unilateral freezing of 
funds without a specific rationale would not only undermine the 
congressional intent behind the enactment of those laws, but also would 
subvert enacted statutes. 
The funding freeze harms people in the districts and States amici 
represent by cutting off services, aid, and grants. The plaintiff States 
have provided evidence that the funding freeze irreparably harms 
residents. Amici’s own expert staff research confirms that the funding 
freeze is causing widespread harm to critical programs and the people 
they serve.  
The funding freeze also harms the legislative process itself. 
Congress presumes that the executive branch will take care to carry out 
the appropriations laws as written. When the executive branch violates 
that expectation with a categorical freeze, it becomes difficult, if not 
impossible, for Congress to properly evaluate and enact new 
appropriations for the upcoming year and beyond. The President’s 
unconstitutional freeze and failure to provide required information thus 
harm Congress’s ability to legislate and impair the effective and 
constitutional operation of our system of government. 

 
4 
ARGUMENT 
I. 
The President may not unilaterally withhold funds based 
on his own priorities or policy preferences. 
A categorical funding freeze that fails to carry out the 
appropriations laws is unconstitutional. The President’s orders and 
actions are based on a misconception of his authority.  
A. 
Congress has the exclusive power to appropriate 
funds and to make laws governing their use. 
While it is sometimes said that the Constitution creates three 
“coequal” branches, this is merely shorthand for the proposition that no 
one branch exercises the whole power of government.1 When it comes to 
the specified powers that the Constitution grants to each branch of 
government, the separate branches are not equal at all. The power to 
make law belongs exclusively to Congress.2 Under our Constitution, 
Congress alone has broad authority to impose taxes and appropriate 
funds to provide for our defense and general welfare.3 This power is of 
 
1 Mistretta v. United States, 488 U.S. 361, 380 (1989). 
2 Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579, 587-88 (1952). 
3 U.S. Const. art. I, § 8, cl. 1. 

 
5 
paramount importance, which is why it is dispersed among 435 
representatives in the House and 100 senators.4  
An appropriation is the legal authority to incur obligations and 
make payment from the Treasury for specified purposes.5 
Appropriations must be spent to fulfill their purpose.6 Therefore, 
“unless Congress has enacted a law providing otherwise, the President 
must take care to ensure that appropriations are prudently obligated 
during their period of availability.”7 An appropriations law must be 
faithfully executed to implement congressional policy; it is not a mere 
recommendation for the President to consider. 
A President may not like the purpose for which Congress 
appropriated funds, but this is not a permissible reason to refuse to 
 
4 See INS v. Chadha, 462 U.S. 919, 950 (1983) (recognizing “the need to 
divide and disperse power in order to protect liberty,” including the 
legislative power, which “‘necessarily predominates’” (quoting The 
Federalist No. 51)); Clinton v. City of New York, 524 U.S. 417, 450 
(1998) (Kennedy, J., concurring) (citing The Federalist No. 47). 
5 See U.S. Gov’t Accountability Off. (GAO), GAO-16-464SP, Principles of 
Federal Appropriations Law 2-3 (4th ed. 2016), https://www.gao.gov/
assets/2019-11/675709.pdf; 2 U.S.C. § 622(2)(A)(i). 
6 See 31 U.S.C. § 1301(a); U.S. Dep’t of Navy v. Fed. Lab. Rels. Auth., 
665 F.3d 1339, 1348 (D.C. Cir. 2012) (Kavanaugh, J.).  
7 OMB–Withholding of Ukraine Security Assistance, B-331564, 2020 
WL 241373, at *4 (Comp. Gen. Jan. 16, 2020). 

 
6 
carry out the law. The President and federal agencies may not decline 
to follow statutes that require expenditures, even if the President 
believes the expenditures to be contrary to the policy that the President 
would enact if they possessed appropriations authority.8 If the 
President or agencies could decline to make expenditures based on 
policy disagreements, then the President alone would remake the law 
by honoring some statutes and disregarding others.9  
After Congress passes a bill and a President signs it, the bill is 
enacted into law. A President may not then unilaterally change it.10 If 
an incoming President believes that the law should change, then the 
President must “recommend” such changes to Congress for its 
“Consideration.”11 This process ensures that laws have stable meaning; 
they do not lose their force and effect merely because voters elect a new 
President. As the U.S. Supreme Court regularly states, those who wish 
 
8 In re Aiken County, 725 F.3d 255, 259 (D.C. Cir. 2013) (Kavanaugh, J.) 
(“[T]he President may not decline to follow a statutory mandate or 
prohibition simply because of policy objections.”). 
9 OMB–Withholding of Ukraine Security Assistance, B-331564, supra, 
at *6 (“Faithful execution of the law does not permit the President to 
substitute his own policy priorities for those that Congress has enacted 
into law.”). 
10 Chadha, 462 U.S. at 954 & n.18. 
11 U.S. Const. art. II, § 3; Clinton, 524 U.S. at 438. 

 
7 
to change the laws should address their request to Congress.12 An 
appropriation is a law like any other under the Constitution.13 
Accordingly, if the President seeks to change an appropriation, he must 
address that request to Congress. 
B. 
The executive orders required a funding freeze based 
on a misconception of presidential power.  
The executive orders and OMB memorandum at issue do not 
contain any analysis or reasoning particular to any law or facts. 
Instead, they impose a broad and categorical freeze on vast swaths of 
funding with no justification outside the stated intent to change United 
States policy to align with presidential priorities. Even if the freeze had 
been implemented on an individualized basis after a case-by-case 
funding analysis, the law precludes the President from even 
temporarily freezing or deferring funding based on his policy 
preferences alone.  
 
12 NCAA v. Alston, 594 U.S. 69, 96 (2021); Consumer Prod. Safety 
Comm’n v. GTE Sylvania, Inc., 447 U.S. 102, 124 (1980); James v. 
United States, 366 U.S. 213, 235 (1961) (Black, J., concurring in part 
and dissenting in part). 
13 Consumer Fin. Prot. Bureau v. Cmty. Fin. Servs. Ass’n of Am., Ltd., 
601 U.S. 416, 424 (2024) (“[A]n appropriation is simply a law that 
authorizes expenditures from a specified source of public money for 
designated purposes.”). 

 
8 
In issuing executive orders and an OMB memorandum that froze 
all funding across a broad range of activities and agencies, the 
President and OMB presumed that all such funding should be halted—
in some cases permanently—to permit the President to implement his 
own priorities and policy preferences. This was a categorical freeze on 
spending, emanating first from the President in his executive orders 
and then effectuated by OMB. As this Court concluded in ruling on 
defendants’ stay motion, the relevant agencies did not make any 
individualized assessments about whether to defer spending, but 
instead complied with a broad executive command to halt.14 
The President’s and OMB’s categorical funding-freeze orders 
directly contravene our constitutional design. The OMB memorandum 
initiating the categorical funding freeze seeks to implement the 
President’s mistaken view that he alone embodies the popular will. It 
states, “Career and political appointees in the Executive Branch have a 
duty to align Federal spending and action with the will of the American 
people as expressed through Presidential priorities.”15  
 
14 See New York v. Trump, 133 F.4th 51, 68-69 (1st Cir. 2025). 
15 OMB, Exec. Off. of the President, Memorandum M-25-13 (Jan. 27, 
2025), https://www.whitehouse.gov/wp-content/uploads/2025/03/M-25-
13-Temporary-Pause-to-Review-Agency-Grant-Loan-and-Other-
Financial-Assistance-Programs.pdf. 

 
9 
Not so. Voters do not vote for one person to carry their will into 
effect. The voters choose not only a President, but also representatives16 
and senators.17 The Constitution gave the “power over the purse” to 
these “immediate representatives of the people”—representatives and 
senators in Congress—for “carrying into effect every just and salutary 
measure.”18 Members of Congress act collectively to pass laws which, if 
signed by a President or approved by two-thirds of both houses of 
Congress, will endure until some lawful countervailing force repeals or 
strikes them down.  
President Trump and OMB are wrong to claim his priorities, 
policies, and requirements are a sufficient justification to override 
appropriations laws. His duty is to take care “that the Laws be 
faithfully executed,”19 not to refuse to execute the laws.20 Winning a 
presidential election does not give him a “mandate” to override our 
 
16 U.S. Const. art. I, § 2. 
17 U.S. Const. art. I, § 3; U.S. Const. amend. XVII. 
18 United States v. Munoz-Flores, 495 U.S. 385, 395 (1990) (quoting The 
Federalist No. 58). 
19 U.S. Const. art. II, § 3. 
20 OMB–Withholding of Ukraine Security Assistance, B-331564, supra, 
at *6 (“Faithful execution of the law does not permit the President to 
substitute his own policy priorities for those that Congress has enacted 
into law.”). 

 
10 
nation’s laws. Our federal laws are the product of a deliberate and 
“exhaustively considered” process,21 and the bargains and compromises 
reflected in those laws are based on the assumption that the laws will 
be enforced. The President lacks authority to block them.  
II. 
The President’s failure to carry out the law harms the 
constituents of amici and Congress itself.  
The President’s unlawful orders and actions harm people by 
freezing funds for essential programs. And they harm Congress by 
hindering its ability to legislate. 
A. 
The funding freeze harms people. 
In addition to the irreparable harms identified by the plaintiffs, 
amici’s staff have compiled an extensive (but not exhaustive) list of 
programs affected by the President’s unlawful funding freeze.22 These 
programs serve people throughout the United States and in the home 
States of amici. Freezing funding for these programs directly harms 
constituents of amici. 
 
21 Chadha, 462 U.S. at 951. 
22 Appropriations Comm. Democrats, Trump’s Unprecedented Funding 
Freeze Hits Communities Across America, https://democrats-
appropriations.house.gov/trumps-unprecedented-funding-freeze-hits-
communities-across-america (last visited July 25, 2025). 

 
11 
Under the Administration’s orders, for example, the Department 
of Education has frozen funding for K-12 schools in every State, 
disrupting the ability of school districts to plan, budget, and spend 
federal payments for the upcoming school year.23 AmeriCorps 
terminated agreements and removed members, affecting more than 
1,000 programs and 30,000 AmeriCorps participants.24 The Department 
of Agriculture has frozen funding for farmers to conserve their land and 
water.25 And it has frozen funding to reduce wildfire risk.26 As the court 
 
23 See Michael A. DiNapoli Jr. et al., States Face Uncertainty as an 
Estimated $6.2 Billion in K-12 Funding Remains Unreleased: Here’s the 
Fiscal Impact by State, Learning Pol’y Inst. (June 30, 2025), 
https://learningpolicyinstitute.org/blog/states-face-uncertainty-k-12-
funding-remains-unreleased; Bianca Vázquez Toness, More Than 20 
States Sue Trump Administration over Frozen After-School and 
Summer Funding, AP (July 14, 2025), https://apnews.com/article/boys-
girls-club-trump-grant-freeze-6f5bd3204d2973784d466e3f0fdb38b4. 
24 See Maryland v. Corp. for Nat’l & Cmty. Serv., Civ. No. DLB-25-1363, 
2025 WL 1585051, at *1 (D. Md. June 5, 2025); Elev8 Balt., Inc. v. Corp. 
for Nat’l & Cmty. Serv., Civ. No. MJM-25-1458, 2025 WL 1865971, at 
*6-7 (D. Md. July 7, 2025). 
25 USDA has frozen funding for many programs. See Linda Qiu et al., 
Trump’s Funding Freezes Bruise a Core Constituency: Farmers, N.Y. 
Times (Feb. 13, 2025), www.nytimes.com/2025/02/13/us/politics/trump-
funding-freeze-farmers.html; see generally Trump’s Unprecedented 
Funding Freeze Hits Communities Across America, supra. 
26 USDA and the Bureau of Land Management have frozen funds to 
remove fuels on forest grounds, affecting “some of the densest, most 
fire-prone places” in the country. Morgan Rothborne, Lomakatsi: Fed 
Funds Freeze Means Employee Layoffs, Fewer Prescribed Burns, 
 

 
12 
ruled in this case, FEMA has frozen numerous grants, leaving States 
and localities less able to respond to natural disasters.27 The 
Environmental Protection Agency has frozen grants for solar 
installation and energy efficiency projects, which would reduce 
constituents’ energy bills.28  
The Department of Justice has frozen grants for numerous 
programs, including grants from the Office on Violence Against 
Women.29 The National Science Foundation has terminated more than 
1,600 grants, jeopardizing crucial research and innovation.30 The 
 
Ashland.news (Mar. 7, 2025), https://ashland.news/lomakatsi-fed-funds-
freeze-means-employee-layoffs-fewer-prescribed-burns.  
27 New York v. Trump, C.A. No. 25-cv-39, 2025 WL 1009025, at *2 
(D.R.I. Apr. 4, 2025). 
28 See Climate United Fund v. Citibank, N.A., No. 25-cv-698, 2025 WL 
1131412, at *4-5 (D.D.C. Apr. 16, 2025); Claire Brown, E.P.A. Offers No 
New Evidence in Battle over $20 Billion in Climate Grants, N.Y. Times 
(Mar. 17, 2025), www.nytimes.com/2025/03/17/climate/epa-gold-bars-
climate-lawsuit.html. 
29 See Maggie Dresser, Federal Funding Freezes Have Chilling Effect on 
Rural Domestic Violence Resources, Flathead Beacon (Apr. 30, 2025), 
https://flatheadbeacon.com/2025/04/30/federal-funding-freezes-have-
chilling-effect-on-rural-domestic-violence-resources.   
30 See Thakur v. Trump, No. 25-cv-04737, 2025 WL 1734471, at *5 & 
n.16 (N.D. Cal. June 23, 2025), appeal docketed, No. 25-4249 (9th Cir. 
July 10, 2025). 

 
13 
Department of Energy has frozen numerous grants for clean energy and 
nuclear energy projects.31  
The National Endowment for the Arts has frozen many grants, 
leaving smaller artists without critical support.32 The Department of 
Transportation has frozen grants for critical infrastructure, as the 
district court found in this case.33 It has also frozen funding for electric 
vehicle charging stations.34 The Department of Health and Human 
 
31 See Woonasquatucket River Watershed Council v. USDA, No. 25-cv-
00097, 2025 WL 1116157, at *6 (D.R.I. Apr. 15, 2025), appeal docketed, 
No. 25-1428 (1st Cir. May 1, 2025); Sara Wilson, Memorandum for All 
DOE Funding Agreements or Awards (Jan. 27, 2025), 
www.appropriations.senate.gov/imo/media/doc/250131_murray_kaptur_
letter_to_doe_with_addendum.pdf (page 8 of PDF file). 
32 See Chloe Veltman, Sweeping Cuts Hit NEA After Trump 
Administration Calls to Eliminate the Agency, NPR (May 5, 2025), 
www.npr.org/2025/05/03/nx-s1-5385888/sweeping-cuts-hit-nea-after-
trump-administration-calls-to-eliminate-the-agency. 
33 New York v. Trump, 769 F. Supp. 3d 119, 144 (D.R.I. 2025); see 
Sustainability Inst. v. Trump, No. 25-cv-2152, 2025 WL 1486979, at *3 
& n.5 (D.S.C. May 20, 2025), appeal docketed, No. 25-1575 (4th Cir. May 
22, 2025). 
34 See U.S. Department of Transportation, Federal Highway 
Administration–Application of the Impoundment Control Act to 
Memorandum Suspending Approval of State Electric Vehicle 
Infrastructure Deployment Plans, B-337137, 2025 WL 1521234, at *10-
11 (Comp. Gen. May 22, 2025) (concluding that DOT improperly 
withheld funds to be expended under the National Electric Vehicle 
Infrastructure Formula Program); Washington v. U.S. Dep’t of Transp., 
No. 25-cv-00848, 2025 WL 1742893, at *10-15 (W.D. Wash. June 24, 
2025). 

 
14 
Services has frozen part of the funding for Head Start, causing some 
preschools to close their doors and sending families scrambling to try to 
find other preschool options.35 The Centers for Disease Control and 
Prevention has frozen part of the funding for state and local health 
departments, causing these health departments to cancel prevention 
programs related to heart disease and stroke, HIV, and sexually 
transmitted infections, as well as to lay off public health staff who may 
not be available to return if the funding is ever made available again.36  
These are only a few examples. The categorical funding freeze 
affects every department of government and tens of thousands of 
grants. The President has no authority to carry out a categorical freeze 
across all agencies, which defeats the purposes of appropriations and 
causes widespread harm. 
 
35 See Cheyanne Mumphrey, Head Start Funding Lags by Nearly $1 
Billion This Year, Causing Some Preschool Closures, AP (Apr. 16, 2025), 
https://apnews.com/article/head-start-funding-preschool-child-care-
closures-1f92fa98f320c7c14db63e69b986d11d. 
36 See Selena Simmons-Duffin, ‘Where’s Our Money?’ CDC Grant 
Funding Is Moving So Slowly Layoffs Are Happening, NPR (June 28, 
2025), www.npr.org/sections/shots-health-news/2025/06/28/nx-s1-
5442689/cdc-trump-layoffs-public-health-rescission. 

 
15 
B. 
The funding freeze harms the legislative process. 
Congress’s legislative function—which is iterative and ongoing—
requires the predictable execution of laws and information about the 
implementation of those laws. Congress’s constitutional appropriations 
function is no different. In determining how much funding to 
appropriate for any activity, now or in the future, Congress presumes 
that the executive branch will prudently obligate and expend previous 
appropriations, thus carrying out the enacted laws. If Congress cannot 
trust the executive to carry out appropriations laws, it cannot legislate 
wisely or effectively, and will not know whether or how much to 
appropriate for an activity at any given time.  
The statutory structure of the annual budget-and-appropriations 
process—through which Congress has annually appropriated at least $3 
trillion in recent years—reflects Congress’s need for reliable execution 
of the appropriations laws.37 The statutes provide that the President 
 
37 See H.R. Rep. No. 118-966, at 8-11 (2025), https://www.congress.gov/
118/crpt/hrpt966/CRPT-118hrpt966.pdf. 

 
16 
will submit a detailed budget,38 after which agency personnel may 
submit additional materials to relevant House and Senate 
appropriations committees.39 After receiving materials from federal 
agencies, the appropriations subcommittees compile written reports to 
accompany appropriations bills.40 These reports are typically the 
subject of extensive input and contain detailed directions for applying 
federal funds, some portions of which are often statutorily incorporated 
to give them the force of law.41 This statutory process is repeated in 
both chambers of Congress, and requires extensive interbranch 
coordination and precise targeting of funding to match ongoing needs.  
 
38 2 U.S.C. § 631; Congressional Research Service, R42388, The 
Congressional Appropriations Process: An Introduction 2 (2016), 
https://crsreports.congress.gov/product/pdf/R/R42388; see OMB, Exec. 
Off. of the President, Circular No. A-11, Preparation, Submission, and 
Execution of the Budget (July 2024), 
https://bidenwhitehouse.archives.gov/wp-content/uploads/2018/06/
a11.pdf. 
39 The Congressional Appropriations Process: An Introduction, supra, at 
3; Congressional Research Service, RS20268, Agency Justification of the 
President’s Budget 1 (2008), www.congress.gov/crs_external_products/
RS/PDF/RS20268/RS20268.8.pdf. 
40 Congressional Research Service, R44124, Appropriations Report 
Language: Overview of Development and Components 1 (2023), 
https://sgp.fas.org/crs/misc/R44124.pdf. 
41 See id. at 2-5. 

 
17 
This process breaks down when, as here, the President refuses to 
obligate or expend appropriated funds. Unlawful impoundments 
subvert the interbranch coordination inherent in the annual budget and 
appropriations process: They create doubt about whether hard-fought 
compromises and trade-offs will be honored, which deprives lawmakers 
of the incentives to make deals and threatens to make it impossible to 
pass appropriations laws. An arbitrary across-the-board freeze creates 
even more confusion because Congress does not know whether or when 
the President will “unfreeze” any given funds. When funds are frozen, 
Congress does not know whether the President’s intent was to cancel 
the program or alter spending levels, both of which are beyond his 
authority. Either way, Congress cannot appropriate funds effectively 
when the President’s enforcement of appropriations laws is 
unpredictable. This subversion of trust applies not just to the annual 
budget and appropriations process, but to the myriad appropriations 
considered in authorizing legislation at both ad hoc and regular 
intervals. 
The President’s categorical funding freeze also violates the 
Impoundment Control Act of 1974 (ICA), and thus defies congressional 
authority to control appropriations. Before Congress enacted the ICA, 
the Antideficiency Act had permitted a President to establish “reserves 

 
18 
. . . to provide for contingencies, or to effect savings whenever savings 
are made possible by or through changes in requirements, greater 
efficiency of operations, or other developments subsequent to the date on 
which an appropriation is made available.”42 The Nixon Administration 
purported to rely on the “developments subsequent” provision of the 
Antideficiency Act in freezing funds.43 The ICA amended the 
Antideficiency Act to remove that authority.44 
Under the ICA, the President’s authority to defer or withhold 
appropriated funds is extremely limited and does not authorize the 
categorical freeze at issue here.45 Deferrals are permissible only to 
provide for contingencies, achieve savings made possible by or through 
changes in requirements or greater efficiency of operations, or as 
 
42 General Appropriation Act, 1951, ch. 896, § 1211, 64 Stat. 595, 765-66 
(1950) (emphasis added) (amending Section 3679 of the Revised 
Statutes). 
43 See Note, Impoundment of Funds, 86 Harv. L. Rev. 1505, 1517 (1973). 
44 Impoundment Control Act of 1974, Pub. L. No. 93-344, tit. X, § 1002, 
88 Stat. 297, 332. 
45 This limited authority to defer or withhold does not supersede “any 
provision of law which requires the obligation of budget authority or the 
making of outlays thereunder.” 2 U.S.C. § 681(4). 

 
19 
required by law.46 Conforming to the President’s policy preferences is 
not a permissible reason for deferral under the ICA.  
Even if the President had a valid reason for seeking to defer or 
withhold appropriated funds, the ICA requires the President to 
transmit a “special message” before deferring or withholding 
appropriated funds.47 The “special message” must provide a detailed 
analysis of all circumstances pertaining to the deferral or proposed 
rescission of funding.48 Once the special message is delivered, the 
Comptroller General, the director of the Government Accountability 
Office (GAO), reviews the proposed spending deferral to assess whether 
it “is in accordance with existing statutory authority,” including 
whether any withheld funding is permitted to be frozen within the 
limits of the specific authority granted by the ICA.49 
 
46 Id. § 684(b). 
47 Id. §§ 683, 684(a). 
48 Id. § 684(a)(6).  
49 Id. § 685(b)(2). The President appoints the Comptroller General, by 
and with the advice and consent of the Senate, to a fifteen-year term. 31 
U.S.C. § 703(a)(1), (b). The President may not remove the Comptroller 
General. He or she may be removed only by impeachment or joint 
resolution of Congress. Id. § 703(e)(1); see Impoundment Control Act–
Withholding of Funds Through Their Date of Expiration, B-330330, 
2018 WL 6445752 (Comp. Gen. Dec. 10, 2018). 

 
20 
Thus, before withholding appropriated funds from obligation or 
expenditure, the ICA requires the executive branch to initiate and 
participate in a regimented and deliberate dialogue with Congress. The 
information that the executive branch provides under this process 
enables Congress to consider, on a case-by-case basis, whether it (and 
not the executive) wishes to alter spending laws, demonstrating that 
the narrow authority Congress granted to the executive in the ICA to 
freeze funding is conditioned upon the provision of information to 
Congress.  
The President and OMB did not seek to use the authority in the 
ICA by identifying funding that would be eligible to be temporarily 
withheld under such law and transmitting the statutorily required 
special messages that would allow for limited temporary withholdings 
of such amounts. But even if they had transmitted a special message for 
the amounts subject to the categorical funding freeze, this would not 
have cured violation of the ICA and appropriations laws, as the ICA 
permits deferral only for narrow purposes. The funding freeze was not 
merely a procedural oversight, but a substantive violation of the 
statutory framework and Congress’s appropriations power. That is, it 
was unconstitutional and illegal under the ICA and has the practical 
effect of harming Congress’s ability to legislate future appropriations. 
 
 

 
21 
CONCLUSION 
President Trump’s executive orders and the OMB memorandum 
assume that voters not only elected a Commander in Chief, but also 
vested, in one person, a legislative power to pause, reevaluate, and 
potentially override every law that was enacted before he took office. 
This Court should firmly reject that premise and affirm the order 
enjoining the executive orders and OMB memorandum in this case.  
July 25, 2025 
 
Maura Eileen O’Connor 
THE BRENNAN CENTER FOR 
JUSTICE AT NYU SCHOOL OF LAW 
1140 Connecticut Ave., NW 
11th Floor, Suite 1150 
Washington, DC 20036 
Telephone: (202) 249-7190 
Respectfully submitted, 
 
By: s/ Brian A. Sutherland  
  
Brian A. Sutherland 
Melanie C. Gold 
COMPLEX APPELLATE  
LITIGATION GROUP LLP 
96 Jessie Street 
San Francisco, CA 94105 
Telephone: (415) 649-6700 
 
 
Attorneys for Amici Curiae 157 Members of Congress

 
 
 
CERTIFICATE OF COMPLIANCE 
Counsel for Amici Curiae 157 Members of Congress represents: 
1. 
This brief complies with the type-volume limitation of 
Federal Rule of Appellate Procedure 29(a)(5). This brief contains 4,067 
words, excluding the parts of the brief exempted by Federal Rule of 
Appellate Procedure 32(f). 
2. 
This brief complies with the typeface requirements of 
Federal Rule of Appellate Procedure 32(a)(5) and the typestyle 
requirements of Federal Rule of Appellate Procedure 32(a)(6). This brief 
has been prepared in a proportionally spaced typeface using Microsoft 
Word in 14-point Century Schoolbook font. 
July 25, 2025 
s/ Brian A. Sutherland  
  
 Brian A. Sutherland 

 
 
CERTIFICATE OF SERVICE 
I hereby certify that on July 25, 2025, I electronically filed the 
foregoing brief with the Clerk of the Court for the United States Court 
of Appeals for the First Circuit using the CM/ECF system. I further 
certify that all participants in the case are registered CM/ECF users 
and that service will be accomplished by the CM/ECF system. 
July 25, 2025 
s/ Brian A. Sutherland  
  
 Brian A. Sutherland 
 

1 
APPENDIX: LIST OF AMICI CURIAE 
 
Jamie Raskin 
Representative of 
Maryland 
 
Rosa L. DeLauro 
Representative of 
Connecticut 
 
Hakeem Jeffries 
Representative of 
New York 
 
Katherine Clark 
Representative of 
Massachusetts 
 
Pete Aguilar 
Representative of 
California 
 
Joe Neguse 
Representative of  
Colorado 
 
Gabe Amo 
Representative of 
Rhode Island 
 
Jake Auchincloss 
Representative of 
Massachusetts  
Becca Balint 
Representative of  
Vermont 
 
Nanette Barragán 
Representative of 
California 
 
Joyce Beatty 
Representative of  
Ohio 
 
Wesley Bell 
Representative of  
Missouri 
 
Donald S. Beyer Jr. 
Representative of  
Virginia 
 
Sanford D. Bishop, Jr. 
Representative of  
Georgia 
 
Suzanne Bonamici 
Representative of  
Oregon 
 
Brendan F. Boyle 
Representative of 
Pennsylvania 

2 
Shontel Brown 
Representative of  
Ohio 
 
Julia Brownley 
Representative of 
California 
 
Nikki Budzinski 
Representative of  
Illinois 
 
Janelle Bynum 
Representative of  
Oregon 
 
Salud O. Carbajal 
Representative of 
California 
 
André Carson 
Representative of  
Indiana 
 
Troy A. Carter, Sr. 
Representative of 
Louisiana  
 
Ed Case 
Representative of  
Hawaii 
 
Sean Casten 
Representative of  
Illinois 
 
Kathy Castor 
Representative of  
Florida 
 
Sheila Cherfilus-
McCormick 
Representative of  
Florida 
 
Judy Chu 
Representative of 
California 
 
Gilbert R. Cisneros, Jr. 
Representative of 
California 
 
Yvette Clarke 
Representative of  
New York 
 
James E. Clyburn 
Representative of  
South Carolina 
 
Steve Cohen 
Representative of 
Tennessee 
 

3 
J. Luis Correa 
Representative of 
California 
 
Jim Costa 
Representative of 
California 
 
Joe Courtney 
Representative of 
Connecticut 
 
Angie Craig 
Representative of 
Minnesota  
 
Jasmine Crockett 
Representative of  
Texas 
 
Danny K. Davis 
Representative of  
Illinois 
 
Madeleine Dean 
Representative of 
Pennsylvania 
 
Diana DeGette 
Representative of  
Colorado 
 
Suzan K. DelBene 
Representative of 
Washington 
 
Chris Deluzio 
Representative of 
Pennsylvania 
 
Mark DeSaulnier 
Representative of 
California 
 
Maxine Dexter 
Representative of  
Oregon 
 
Debbie Dingell 
Representative of  
Michigan 
 
Lloyd Doggett 
Representative of  
Texas 
 
Sarah Elfreth 
Representative of 
Maryland 
 
Veronica Escobar 
Representative of  
Texas 
 

4 
Adriano Espaillat 
Representative of  
New York 
 
Dwight Evans 
Representative of 
Pennsylvania 
 
Cleo Fields 
Representative of 
Louisiana 
 
Lizzie Fletcher 
Representative of  
Texas 
 
Lois Frankel 
Representative of  
Florida 
 
Laura Friedman 
Representative of 
California 
 
Maxwell Alejandro Frost 
Representative of  
Florida 
 
Jesús G. “Chuy” García 
Representative of  
Illinois 
 
Robert Garcia 
Representative of 
California 
 
Sylvia Garcia 
Representative of  
Texas 
 
Dan Goldman 
Representative of  
New York 
 
Maggie Goodlander 
Representative of  
New Hampshire 
 
Josh Gottheimer 
Representative of  
New Jersey 
 
Jim Himes 
Representative of 
Connecticut 
 
Chrissy Houlahan 
Representative of 
Pennsylvania  
 
Steny H. Hoyer 
Representative of 
Maryland 
 

5 
Jared Huffman 
Representative of 
California 
 
Glenn F. Ivey 
Representative of 
Maryland  
 
Jonathan L. Jackson 
Representative of  
Illinois 
 
Sara Jacobs 
Representative of 
California 
 
Pramila Jayapal 
Representative of 
Washington 
 
Henry C. “Hank” 
Johnson, Jr. 
Representative of  
Georgia 
 
Julie Johnson 
Representative of  
Texas 
 
Sydney Kamlager-Dove 
Representative of 
California 
 
Marcy Kaptur 
Representative of  
Ohio 
 
William Keating 
Representative of 
Massachusetts  
 
Robin L. Kelly 
Representative of  
Illinois 
 
Timothy M. Kennedy 
Representative of  
New York 
 
Ro Khanna 
Representative of 
California 
 
Greg Landsman 
Representative of  
Ohio 
 
Rick Larsen 
Representative of 
Washington 
 
George Latimer 
Representative of  
New York 
 

6 
Susie Lee 
Representative of  
Nevada 
 
Teresa Leger Fernández 
Representative of  
New Mexico 
 
Mike Levin 
Representative of 
California 
 
Sam T. Liccardo 
Representative of 
California 
 
Ted W. Lieu 
Representative of 
California 
 
Zoe Lofgren 
Representative of 
California 
 
Stephen F. Lynch 
Representative of 
Massachusetts  
 
Seth Magaziner 
Representative of  
Rhode Island 
 
John W. Mannion 
Representative of  
New York 
 
Doris Matsui 
Representative of 
California 
 
Lucy McBath 
Representative of  
Georgia 
 
April McClain Delaney 
Representative of 
Maryland 
 
Jennifer L. McClellan 
Representative of  
Virginia 
 
Betty McCollum 
Representative of 
Minnesota 
 
Kristen McDonald Rivet 
Representative of 
Michigan 
 
James P. McGovern 
Representative of 
Massachusetts  
 

7 
LaMonica McIver 
Representative of  
New Jersey 
 
Gregory W. Meeks 
Representative of  
New York 
 
Grace Meng 
Representative of  
New York 
 
Kweisi Mfume 
Representative of 
Maryland 
 
Dave Min 
Representative of 
California 
 
Gwen S. Moore 
Representative of 
Wisconsin 
 
Joseph D. Morelle 
Representative of  
New York 
 
Kelly Morrison 
Representative of 
Minnesota 
 
Jared Moskowitz 
Representative of  
Florida 
 
Seth Moulton 
Representative of 
Massachusetts 
 
Frank J. Mrvan 
Representative of  
Indiana 
 
Kevin Mullin 
Representative of 
California 
 
Jerrold Nadler 
Representative of  
New York 
 
Richard E. Neal 
Representative of 
Massachusetts 
 
Eleanor Holmes Norton 
Representative of the 
District of Columbia 
 
Johnny Olszewski 
Representative of 
Maryland 
 
 

8 
Frank Pallone, Jr. 
Representative of  
New Jersey 
 
Jimmy Panetta 
Representative of 
California 
 
Nancy Pelosi 
Representative of 
California 
 
Brittany Pettersen 
Representative of 
Colorado 
 
Chellie Pingree 
Representative of  
Maine 
 
Mark Pocan 
Representative of 
Wisconsin 
 
Nellie Pou 
Representative of  
New Jersey 
 
Mike Quigley 
Representative of  
Illinois 
 
Delia C. Ramirez 
Representative of  
Illinois 
 
Emily Randall 
Representative of 
Washington 
 
Luz M. Rivas 
Representative of 
California 
 
Deborah K. Ross 
Representative of  
North Carolina 
 
Andrea Salinas 
Representative of  
Oregon 
 
Mary Gay Scanlon 
Representative of 
Pennsylvania 
 
Jan Schakowsky 
Representative of  
Illinois 
 
Bradley Scott Schneider 
Representative of  
Illinois 
 

9 
Robert C. “Bobby” Scott 
Representative of  
Virginia 
 
Brad Sherman 
Representative of 
California 
 
Mikie Sherrill 
Representative of  
New Jersey 
 
Darren Soto 
Representative of  
Florida 
 
Melanie A. Stansbury 
Representative of  
New Mexico 
 
Greg Stanton 
Representative of  
Arizona 
 
Marilyn Strickland 
Representative of 
Washington 
 
Suhas Subramanyam 
Representative of  
Virginia 
 
Eric Swalwell 
Representative of 
California 
 
Mark Takano 
Representative of 
California 
 
Shri Thanedar 
Representative of 
Michigan 
 
Bennie G. Thompson 
Representative of 
Mississippi 
 
Mike Thompson 
Representative of 
California 
 
Dina Titus 
Representative of  
Nevada 
 
Paul D. Tonko 
Representative of  
New York 
 
Norma J. Torres 
Representative of 
California 
 

10 
Ritchie Torres 
Representative of  
New York 
 
Lori Trahan 
Representative of 
Massachusetts 
 
Derek T. Tran 
Representative of 
California 
 
Lauren Underwood 
Representative of  
Illinois  
 
Juan Vargas 
Representative of 
California 
 
Marc Veasey 
Representative of  
Texas 
 
Nydia M. Velázquez 
Representative of  
New York 
 
 
 
 
 
 
Debbie Wasserman Schultz 
Representative of  
Florida 
 
Maxine Waters 
Representative of 
California 
 
Bonnie Watson Coleman 
Representative of  
New Jersey 
 
George T. Whitesides 
Representative of 
California 
 
Nikema Williams 
Representative of  
Georgia 
 
Frederica S. Wilson 
Representative of  
Florida

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