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Enforcement ActionLow RiskMultistate

AG Rayfield Sues Trump Administration Over TANF Data Sharing Policy

Administration for Children and Families (ACF)August 3, 2026Oregon Attorney General

Summary

Oregon Attorney General Dan Rayfield, joined by a coalition of 23 other states, the District of Columbia, and two governors, sued the Trump administration to block a new policy by the Administration for Children and Families (ACF) that would allow federal officials to access private records of millions of TANF recipients. The coalition argues the policy illegally shares sensitive personal data, including Social Security numbers and immigration status, with other federal agencies and private organizations, violating the Administrative Procedure Act and the Spending Clause. The lawsuit seeks to declare the policy illegal and block it from taking effect.

Remedy

The coalition is asking the court to declare the ACF policy illegal and block it from taking effect, preventing the sharing of TANF recipients' private data with federal agencies and private organizations.

Injunction

Contract Impact

In-house legal teams for state agencies, contractors, and vendors handling TANF or other public assistance data should review their data processing agreements, confidentiality clauses, and provisions governing responses to government data requests. Specifically, they should ensure that any data sharing with federal agencies is explicitly authorized by law and that contracts include robust privacy protections, limitations on data use, and requirements for consent or notice to beneficiaries. Vendor agreements should be checked for clauses that allow broad data sharing with third parties or government entities without adequate safeguards, and for indemnification provisions related to unauthorized data disclosures.

Contract Search Terms

data sharing agreementgovernment data accessTANF dataconfidentiality clausedata protectionprivacy policyconsent for data sharingfederal agency data requestsimmigration status databeneficiary data

Laws Cited

Administrative Procedure ActSpending Clause of the U.S. Constitution

Violation Types

Entity Details

Entity

Administration for Children and Families (ACF)

Industry

Other

Multistate Coalition

Official Sources

Source Evidence

Entity Name
"the Administration for Children and Families (ACF)"
Laws Cited
"violates the Administrative Procedure Act and the Spending Clause of the U.S. Constitution"
Violation Types
"share TANF recipients’ Social Security numbers, home addresses, immigration status, and other sensitive information with other federal agencies"
Is Multistate
"a coalition of 23 other states, the District of Columbia, and two governors"

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