It’s Alive! IMLS Revived

Gretchen GardellaNo CommentsBlog, Liblime

The Institute of Museum and Library Services (IMLS), the sole federal agency dedicated to supporting the nation’s libraries and museums, has been at the center of unprecedented legal turmoil in 2025. Following a March executive order aimed at dismantling the agency, multiple lawsuits and federal investigations have shaped the agency’s fate, culminating in landmark judicial decisions that underscore the limits of executive power over congressionally appropriated funds.

Executive Order and Initial Actions

On March 14, 2025, President Trump issued Executive Order 14238, directing the elimination of IMLS

Screenshot 2025 12 04 145436

https://www.whitehouse.gov/presidential-actions/2025/03/continuing-the-reduction-of-the-federal-bureaucracy/

along with six other federal agencies (5, 10). The order mandated that these entities reduce their statutory functions to the minimum required by law. Shortly thereafter, Keith Sonderling, Deputy Secretary of Labor, was installed as acting director of IMLS (7). The administration subsequently placed nearly all of the agency’s approximately 75 employees on administrative leave, terminated roughly 1,200 competitive grants representing more than 90 percent of IMLS’s active competitive grants, dismissed all advisory board members, and halted critical data collection and research activities (5).

These actions occurred despite Congress having appropriated $294.8 million to IMLS for fiscal year 2025 through a continuing resolution passed on the same day as the executive order (2). State library agencies across the country, including those in California, Connecticut, and Washington, received termination notices for previously approved grants, forcing some states to pause library services and implement staff cuts (15).

Government Accountability Office Findings

In June 2025, the nonpartisan Government Accountability Office (GAO) issued a damning report concluding that IMLS violated the 1974 Impoundment Control Act by withholding congressionally appropriated funds (11, 12). The GAO found that IMLS had reduced its spending by more than 50 percent in the first five months of 2025 compared to previous years, obligating only approximately $89.9 million to grantees during this period—less than half the amount distributed in comparable periods of 2024 and 2023 (2).

The GAO determined that beyond grants to states, IMLS obligated only about 19 percent of its remaining budget after canceling millions in contracts and terminating much of its workforce (12). According to GAO General Counsel Edda Emmanuelli Perez, this level of obligation did not suggest a reasonable attempt by the agency to fulfill the purposes of the congressional appropriation (12). The watchdog noted that IMLS failed to respond to multiple requests for information, forcing the investigation to rely on publicly available evidence, including sworn court testimony from Acting Director Sonderling (14).

Parallel Legal Challenges

Two major lawsuits emerged to challenge the administration’s actions. In Rhode Island v. Trump, attorneys general from 21 states filed suit in the U.S. District Court for the District of Rhode Island (2). On May 13, 2025, Judge John J. McConnell issued a preliminary injunction requiring the administration to undo the damage inflicted on IMLS, including recalling employees, reinstating grants, and halting further dismantling efforts (7). This represented a significant victory for the states and library advocates.

Most dramatically, on November 21, 2025, Judge McConnell issued a permanent ruling striking down the Trump administration’s attempts to dismantle IMLS (10). The court found that the administration’s actions were arbitrary, capricious, and contrary to federal law. The ruling permanently prohibits the administration from taking such actions in the future and nullifies all previous efforts to gut the agency (10).

The second lawsuit, American Library Association v. Sonderling, filed in the U.S. District Court for the District of Columbia by the American Library Association and the American Federation of State, County, and Municipal Employees, faced a more challenging path (2). On May 1, Judge Richard J. Leon granted a temporary restraining order that prevented the mass layoff of nearly all IMLS employees scheduled for May 4 (5, 7). However, on June 6, Judge Leon declined to issue a preliminary injunction and questioned whether grant-related matters belonged in federal claims court rather than district court (2). Despite this setback, the case continues, with the Department of Justice recently moving for summary judgment on arguments rejected in the Rhode Island

Screenshot 2025 12 04 150659

https://bookriot.com/government-accountability-office-imls/case.

Current Status and Congressional Response

Following the Rhode Island court’s permanent injunction, IMLS announced in late November 2025 that it would reinstate all terminated federal grants. This decision came after months of uncertainty for hundreds of grant recipients who had entered into legally binding agreements with the agency and delivered services in good faith.

Congressional appropriations committees have responded to the crisis by including funding for IMLS in proposed fiscal year 2026 budgets (13). Both the House and Senate versions include approximately $292 to $295 million for the agency—a modest reduction from previous years but far exceeding the Trump administration’s proposed $6 million closure budget. These figures represent bipartisan opposition to the administration’s efforts to eliminate the agency.

Implications and Ongoing Concerns

The legal battles surrounding IMLS illustrate fundamental tensions between executive authority and congressional appropriations power. The permanent injunction and GAO findings affirm that the executive branch cannot unilaterally nullify duly enacted federal law or refuse to spend congressionally appropriated funds without following proper legal procedures. As the administration has indicated plans to appeal the Rhode Island decision, the ultimate resolution of these issues may extend into 2026 and beyond, leaving libraries and museums across the nation to navigate continued uncertainty about federal support for their essential community services.

 

Sources

  1. Publishers Weekly. “Results Vary in Legal Efforts to Restore IMLS.” June 18, 2025. https://www.publishersweekly.com/pw/by-topic/industry-news/libraries/article/98040-results-vary-in-legal-efforts-to-restore-imls.html 
  2. EveryLibrary. “EveryLibrary Condemns the Trump Administration’s Termination of IMLS Grants.” 2025. https://www.everylibrary.org/trump_termination_imls_grants 
  3. American Library Association. “Federal Court Halts Dismantling of Federal Library Agency in ALA Lawsuit.” May 2025. https://www.ala.org/news/2025/05/federal-court-halts-dismantling-federal-library-agency-ala-lawsuit 
  4. American Library Association. “ALA warns new IMLS acting director not to cut programs required by law.” March 2025. https://www.ala.org/news/2025/03/ala-warns-new-imls-acting-director-not-cut-programs-required-law 
  5. Buttondown. “A Timeline and Update on the Institute for Museum and Library Services.” June 6, 2025. https://buttondown.com/wellsourced/archive/imls-timeline/ 
  6. American Library Association. “FAQ: Executive Order Targeting IMLS.” 2025. https://www.ala.org/faq-executive-order-targeting-imls 
  7. Book Riot. “Trump Overstepped His Authority By Dismantling the IMLS.” June 17, 2025. https://bookriot.com/government-accountability-office-imls/ 
  8. Federal News Network. “GAO finds Trump administration’s second violation of federal spending law.” June 17, 2025. https://federalnewsnetwork.com/agency-oversight/2025/06/gao-finds-trump-administrations-second-violation-of-federal-spending-law/ 
  9. Taxpayers for Common Sense. “Recent GAO Decisions Demonstrate The Limits of Impoundment.” June 26, 2025. https://www.taxpayer.net/budget-appropriations-tax/recent-gao-decisions-demonstrate-the-limits-of-impoundment/ 
  10. Words and Money. “IMLS Says It Will Reinstate All Terminated Grants.” December 2025. https://www.wordsandmoney.com/in-a-major-win-for-libraries-imls-says-it-will-reinstate-all-terminated-grants/ 
  11. Minitex. “IMLS Information.” 2025. https://minitex.umn.edu/imls-information 
  12. Center on Budget and Policy Priorities. “The Trump Administration Is Threatening Libraries, Museums, and Other Nonprofits.” July 7, 2025. https://www.cbpp.org/research/federal-budget/the-trump-administration-is-threatening-libraries-museums-and-other 
  13. American Library Association. (n.d.). FAQ: Executive Order Targeting IMLS. https://www.ala.org/faq-executive-order-targeting-imls 
  14. Heckman, J., & Heckman, J. (2025, June 17). GAO finds the Trump administration’s second violation of federal spending law. Federal News Network – Helping Feds Meet Their Mission. https://federalnewsnetwork.com/agency-oversight/2025/06/gao-finds-trump-administrations-second-violation-of-federal-spending-law/
  15. Dorgelo, C. (2025). The Trump administration is threatening libraries, museums, and other nonprofits that support the arts, humanities, and learning. Center on Budget and Policy Priorities. https://www.cbpp.org/research/federal-budget/the-trump-administration-is-threatening-libraries-museums-and-other