This legal enforcement action involves Oregon Attorney General Dan Rayfield, leading a coalition of 20 states, securing a court victory against the Trump Administration's unlawful attempt to terminate the BRIC disaster preparedness program. The court ruled that the termination violates appropriations laws and the Administrative Procedures Act, requiring restoration of billions in funding to protect communities from natural disasters.
The court order enjoins FEMA from terminating the BRIC program and mandates the restoration of allocated funding to state, tribal, and local governments for disaster mitigation projects.
In-house legal teams should review all grant agreements, cooperative agreements, and sub-award contracts related to federal disaster mitigation funding, particularly those involving FEMA's BRIC program or similar initiatives. Key clauses to examine include termination provisions (to ensure they comply with appropriations laws and prohibit unlawful unilateral termination), funding appropriation references, requirements for cost-effectiveness certifications, and mechanisms for adherence to the Administrative Procedures Act. Teams should also verify clauses mandating compliance with congressional mandates for mitigation, preparation, response, and recovery functions. Changes may be needed to strengthen termination restrictions, explicitly reference appropriations law compliance, and incorporate APA procedural safeguards to prevent future unlawful funding cuts.
Entity
Federal Emergency Management Agency
Also known as: FEMA
Industry
OtherOfficial Press Release
https://www.doj.state.or.us/media-home/news-media-releases/ag-rayfield-secures-court-victory-preventing-trump-from-cutting-disaster-funding/
BRIC MSJ 1
https://www.doj.state.or.us/wp-content/uploads/2025/12/BRIC-MSJ-1.pdf
Oregon Attorney General Enforcement Page
https://www.doj.state.or.us/consumer-protection/
"Federal Emergency Management Agency"
"Appropriations and Spending Clauses"
"Administrative Procedures Act"
"FEMA’s decision to abruptly terminate the BRIC program is in direct violation of Congress’s decision to fund it"
Attorney General Dan Rayfield and a coalition of 21 attorneys general and Pennsylvania filed lawsuits against the U.S. Department of Transportation, FMCSA, and AAMVA to block demands for a database containing personal information of 17 million commercial drivers. The federal government threatened to withhold $10 million in funding unless the data was turned over, which the coalition argues violates privacy law.
Oregon Attorney General Dan Rayfield co-led a coalition of 10 states in a federal lawsuit against the Office of the Comptroller of the Currency (OCC) to block a rule that invalidates state laws requiring mortgage lenders to pay interest on escrow accounts. The lawsuit argues the OCC's rule oversteps federal authority, gives national banks a competitive advantage over state-chartered banks, and takes money away from homeowners.
A federal judge ruled that Nexstar Media Group violated a court order requiring it to keep TEGNA Inc. operating as an independent company while a multistate antitrust lawsuit challenging the merger proceeds. The court found that Nexstar installed its own executives on TEGNA's board, failed to disclose the appointments, and lacked candor with the court. The court ordered Nexstar to comply immediately, file status reports, respond to discovery, and turn over board and financial documents, with a special master to oversee compliance.
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.
Attorney General Dan Rayfield and 49 other state attorneys general sent a letter to the FCC urging stronger 'Know Your Customer' rules to combat illegal robocalls. The coalition requests that phone companies verify customer identities and business practices to prevent scammers from using the network. The letter is part of Phase 2 of Operation Robocall Roundup.
Attorney General Rayfield and a coalition of 49 other attorneys general sent a letter to the FCC urging it to strengthen its Know Your Customer (KYC) rules to combat illegal robocalls. The coalition recommends requiring providers to understand customers' business, applying KYC standards to all providers, and collecting additional information on high-risk customers. No monetary penalty was imposed.