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Enforcement ActionLow RiskMultistate

Attorney General Tong Sues Trump Administration Over Unlawful Sharing of TANF Recipients' Data

Administration for Children and FamiliesAugust 3, 2026Connecticut Attorney General

Summary

Attorney General William Tong joined a coalition of 23 states and the District of Columbia 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 across federal agencies and potentially private organizations. The lawsuit alleges violations of the Administrative Procedure Act and the Spending Clause, seeking to block the policy.

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 with government agencies, particularly those involving the handling of sensitive personal data of benefit recipients. They should examine data sharing clauses to ensure they include strict limitations on secondary use, require consent or legal basis for sharing, and incorporate data minimization principles. Additionally, contracts should include provisions for compliance with federal laws like the Administrative Procedure Act and any applicable privacy regulations, and should address notification requirements if data is shared with other agencies or third parties. Teams should also review subcontractor agreements to ensure downstream data sharing is similarly restricted.

Contract Search Terms

TANF datadata sharing agreementgovernment data accessprivacy safeguardsconsent for data sharingdata minimizationimmigration statusSocial Security numberbenefits datafederal agency data request

Laws Cited

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

Violation Types

Entity Details

Entity

Administration for Children and Families

Industry

Other

Multistate Coalition

ArizonaCaliforniaColoradoDelawareHawaiiIllinoisMaineMarylandMassachusettsMichiganMinnesotaNevadaNew JerseyNew MexicoNew YorkOregonRhode IslandVermontVirginiaWashingtonWisconsinDistrict of ColumbiaKentuckyPennsylvania

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
"illegally shared across the federal government"
Summary
"would give the administration broad access to the sensitive private information of millions of families"

Related Enforcement Actions

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Administration for Children and Families

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.

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