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Enforcement ActionLow RiskMultistate

Multistate Lawsuit Against ACF Over Unlawful TANF Data Sharing

Administration for Children and FamiliesAugust 3, 2026New York Attorney General

Summary

Attorney General Jennifer Davenport joined a coalition of 23 states and DC in suing the Trump Administration over policy changes by the Administration for Children and Families (ACF) that would allow broad sharing of TANF recipients' sensitive personal data with other federal agencies, including ICE. The lawsuit argues the policy violates the Administrative Procedure Act and the Spending Clause, and seeks to block its implementation.

Remedy

The lawsuit seeks a court order declaring ACF's policy illegal and preventing it from being implemented.

Injunction

Contract Impact

In-house legal teams should review any contracts or agreements with federal agencies, particularly those involving the sharing of sensitive personal data such as TANF recipient information. They should ensure that data sharing clauses are narrowly tailored, include restrictions on secondary use, and comply with applicable federal laws like PRWORA. Additionally, contracts should include robust confidentiality and data minimization provisions, and clearly define permissible data uses to prevent unauthorized sharing with other agencies such as ICE.

Contract Search Terms

data sharing agreementgovernment data accessconfidentiality clausedata use restrictionsimmigration status dataTANF datadata minimizationprivacy safeguardsdata transfer restrictionsfederal agency data sharing

Laws Cited

Administrative Procedure ActSpending Clause of the U.S. ConstitutionPersonal Responsibility and Work Opportunity Reconciliation Act (PRWORA)

Violation Types

Entity Details

Entity

Administration for Children and Families

Industry

Other

Multistate Coalition

Official Sources

Source Evidence

Entity Name
"the Administration for Children and Families (ACF) issued a notice"
Laws Cited
"violates the Administrative Procedure Act and the Spending Clause of the U.S. Constitution"
Violation Types
"TANF recipients’ Social Security numbers, addresses, immigration status, and other sensitive personal data would be illegally shared across the federal government"
Is Multistate
"joined a coalition of 23 other states and the District of Columbia"

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