Justice Denied: The Trial of Sonya Massey

By: Pilar Walton
Edited by: Oscar Guzzino and Alexa Tan

“I rebuke you in the name of Jesus,” Sonya Massey said, raising her hands in fear before she was fatally shot in the face. [1] “She’s done. She’s done,” was the response of Officer Sean Grayson after firing the shots. [2] This shooting took place on July 6, 2024, and the verdict was announced on October 29, 2025. For Massey’s family this case represents the racial fault lines that shape encounters between Black Americans and law enforcement. James Wilburn, Massey’s father, stressed that “There’s a difference in this country when you have my skin color and Grayson’s skin color. We need serious justice, not a miscarriage of justice that happened here.” [3]

Massey was a 36-year-old African American mother of two living in Springfield, Illinois. According to her mother Donna, she had a history of mental health struggles and was deeply spiritual. Donna shared that Massey was diagnosed with paranoid schizophrenia. [4] The day before the shooting, Donna called 911 and reported that her daughter was having a mental breakdown. On the call she pleaded, “Please don’t send no combat policemen that are prejudiced. I don’t want you guys to hurt her.” [5] 

On the night of the incident, Massey called 911 because she suspected there was an intruder in her home. Two white policemen, Sean Grayson and Dawson Farley, came to investigate. As seen from body camera footage, Sean Grayson searched the yard before entering her home around 1:15 A.M. Once the deputies entered the house, they noticed a pot of boiling water. Grayson pointed out to Massey, “We don’t need a fire while we’re here,” instructing her to remove it. [6] Massey went to remove the pot while saying, “I rebuke you in the name of Jesus,” words that would soon appear on news headlines across the nation. Grayson, threatened by this response, drew his 9mm pistol and pointed it at her. Both deputies yelled “drop the f—ing pot” before Grayson fired three shots. One of the shots struck Massey below her left eye. At St. John’s Hospital, approximately 26 minutes after the shooting, she was pronounced dead. [7]

The trial began 15 weeks after the shooting and lasted five days before jury deliberation. Attorneys Daniel Fultz and Mark Wykoff represented defendant Sean Grayson, and the prosecution was represented by civil rights attorneys Ben Crump and Antonio Romanucci. On October 22, opening statements began. The prosecution argued that Grayson did not follow police practices, while the defense contended that Grayson was acting in self-defense. Interestingly enough, Officer Dawson Farley, Grayson’s deputy partner, testified against him, revealing that Grayson returned with his medical kit after the shooting but didn’t want to “waste it” on Massey. [8] On the second day, testimony from a forensic pathologist revealed that there was a chance Massey would have survived if she had received medical attention promptly after being shot. During witness examination, when Grayson was asked about his choice not to use his taser, he testified that “[he] did not try to use [his] stun gun because [he] was not sure whether it would work because of Massey’s clothing.” [9] Daniel Fultz, defense attorney, claimed that it was Massey who escalated the situation by picking the pot up and beginning to throw it. However, body camera footage revealed that Masseyimmediately put the pot down once ordered. Fultz argued that Grayson drew his weapon to gain Massey’s compliance and said her death “was a tragedy, but it was not a crime.” [10] On the other hand, Officer Farley asserted that Massey never posed a real threat to either of the officers.

Grayson was originally charged with first-degree murder, but jury instructions included “the option to convict him of a lesser charge of second-degree murder.” [11] The defining factor for first-degree murder is premeditation, meaning the killing must be performed willfully, deliberately, or after planning. [12] Nevertheless, this murder was relegated to the second-degree category on the account that Grayson had an unreasonable belief that his actions were justified. The mitigating factor for second-degree murder in Illinois is belief or provocation, meaning that Grayson should have held a reasonable belief that he was acting in self-defense. An important question then arises: Did Grayson feel that there was a serious provocation and that he had no choice but to draw his weapon? If so, the defense only needs to prove Grayson’s belief of provocation, not his innocence.

The jury consisted of 12 members. Despite Springfield’'s 20 percent Black population, only one of the jury members was Black. Over 12 hours, they examined body camera footage, weighed expert testimony, and evaluated the reasonableness of Massey’s actions. Central to their deliberations was the question of whether Grayson’s use of deadly force could plausibly be understood as self-defense. On October 29, the result of the jury deliberation was revealed: Grayson was found guilty of second-degree murder, facing four to 20 years in prison. Under state law, he could be released in as little as two years due to good behavior. [13] The reality that a man who took the life of an innocent, distressed woman can walk the streets freely after only serving a fraction of his sentence exposes the absurd racial injustices in the American legal system. 

This incident raises deeper concerns about the role of law enforcement in shaping life-or-death outcomes. Officers have the duty to de-escalate volatile situations, especially when responding to calls for assistance. However, the police encounter with Massey, a woman who sought help, displayed no lethal weapons, and attempted to comply with officers’ instructions, ended in her death. Body camera footage and witness testimony make it clear that the force used by Grayson was neither proportionate nor justified. This trial illustrates a larger trend of racial biases shaping law enforcement judgments and who officers deem to be dangerous. 

Massey’s murder triggered national outcry, with intense media coverage and varying views on whether her killing was justified. After the second-degree murder conviction, Massey’s attorneys claimed it was still “a measure of justice for Sonya Massey.” [14] But responses from her family differed. “[How do you] get an officer who says he’s going to shoot you in the face, and then he shoots you in the face, and you only get second-degree murder?” remarked Massey’s cousin. [15] Data shows that it is not common for officers to be charged with murder. Statistics from Bowling Green State University show that law enforcement officers in the U.S. kill approximately 1,000 people per year, but, in 2024, officers were charged with a crime in only 10 out of over 1,200 killings. [16] Such charges are extremely rare as the legal standard gives officers the latitude to use deadly force if necessary. 

The experiences of the many Black victims of police brutality make failures in prosecutorial accountability painfully clear. Massey’s murder is not an isolated issue. It reflects broader systemic deficiencies in policing practices, including inadequate training for responding to individuals with mental health issues, disproportionate fear directed toward Black civilians, and officers who default to violence far too often. This trial resonates with the experiences of other victims like Breonna Taylor, Tanisha Anderson, and Natasha McKenna, exposing the deep-rooted racial oppression that festers in the U.S. to this day. Together, these tragedies highlight the urgent need for structural reform and meaningful prosecutorial accountability within the American legal system.

Notes: 

1. Police Staff, “Former Ill. Deputy on Trial for Murder Testifies about Fatal OIS of Sonya Massey,” Police1, December 12, 2025, https://www.police1.com/legal/former-ill-deputy-on-trial-for-murder-testifies-about-fatal-ois-of-sonya-massey/.

2. Ray Sanchez, “Former Illinois Deputy Found Guilty in Sonya Massey’s Killing,” CNN, October 29, 2025, https://www.cnn.com/2025/10/29/us/sonya-massey-verdict-deputy-guilty.

3. David Greenwald, “Illinois Deputy Convicted in Sonya Massey Killing,” Davis Vanguard, October 29, 2025, https://davisvanguard.org/2025/10/illinois-deputy-convicted-sonya-massey/.

4. KWQC Staff, “Illinois Deputy Found Guilty of Second-Degree Murder in Sonya Massey’s Death,” KWQC-TV6 News, October 29, 2025, https://www.kwqc.com/2025/10/29/illinois-deputy-found-guilty-second-degree-murder-sonya-massey-death/.

5. María Luisa Paúl, “Sonya Massey Called 911 for Help. A Deputy Shot Her Dead,” Washington Post, July 31, 2024, https://www.washingtonpost.com/nation/2024/07/31/sonya-massey-killing-911-calls/.

6. KOMO News Staff, “ ‘Partial Justice’: Father of Sonya Massey Speaks after Former Deputy Found Guilty of Murder,” KOMO News, October 30, 2025, https://komonews.com/news/nation-world/partial-justice-father-of-sonya-massey-speaks-after-former-deputy-found-guilty-of-murder.

7. Sangamon County Sheriff’s Office, “Sonya Massey Information,” Sangamon County Government, accessed December 13, 2025, https://sangamonil.gov/departments/s-z/sheriff/sonya-massey-information.

8. Patrick Yeagle, “Sean Grayson Murder Trial Update: Sonya Massey Opening Arguments, Testimony Recap First Day,” The State Journal-Register, October 23, 2025, https://www.sj-r.com/story/news/politics/courts/2025/10/23/sean-grayson-murder-trial-update-sonya-massey-opening-arguments-testimony-recap-first-day/86836288007/.

9. Daniel Arkin, “Former Illinois Sheriff’s Deputy on Trial in Sonya Massey’s Death Testifies He Thought She Had a Gun,” NBC News, December 12, 2025, https://www.nbcnews.com/news/us-news/former-illinois-sheriff-deputy-trial-sonya-masseys-death-testifies-sho-rcna240034.

10. Arkin, Grayson Trial Testimony. 

11. Yeagle, Grayson Trial Update.

12. Legal Information Institute, “First Degree Murder,” Cornell Law School, accessed December 13, 2025, https://www.law.cornell.edu/wex/first_degree_murder.

13. Arkin, Grayson Trial Testimony.

14. Arkin, Grayson Trial Testimony. 

15. Arkin, Grayson Trial Testimony.

16. Philip M. Stinson, “On-Duty Shootings: Police Officers Charged with Murder or Manslaughter,” Police Integrity Lost: A Study of Law Enforcement Officers Arrested, Bowling Green State University, 2016, https://www.bgsu.edu/content/dam/BGSU/health-and-human-services/document/Criminal-Justice-Program/policeintegritylostresearch/-9-On-Duty-Shootings-Police-Officers-Charged-with-Murder-or-Manslaughter.pdf.

Bibliography:

Arkin, Daniel. “Former Illinois Sheriff’s Deputy on Trial in Sonya Massey’s Death Testifies He Thought She Had a Gun.” NBC News, December 12, 2025. https://www.nbcnews.com/news/us-news/former-illinois-sheriff-deputy-trial-sonya-masseys-death-testifies-sho-rcna240034.

Greenwald, David. “Illinois Deputy Convicted in Sonya Massey Killing.” Davis Vanguard, October 29, 2025. https://davisvanguard.org/2025/10/illinois-deputy-convicted-sonya-massey/.

KOMO News Staff. “‘Partial Justice’: Father of Sonya Massey Speaks after Former Deputy Found Guilty of Murder.” KOMO News, October 30, 2025. https://komonews.com/news/nation-world/partial-justice-father-of-sonya-massey-speaks-after-former-deputy-found-guilty-of-murder.

KWQC Staff. “Illinois Deputy Found Guilty of Second-Degree Murder in Sonya Massey’s Death.” KWQC-TV6 News, October 29, 2025. https://www.kwqc.com/2025/10/29/illinois-deputy-found-guilty-second-degree-murder-sonya-massey-death/.

Legal Information Institute. “First Degree Murder.” Cornell Law School. Accessed December 13, 2025. https://www.law.cornell.edu/wex/first_degree_murder.

Paúl, María Luisa. “Sonya Massey Called 911 for Help. A Deputy Shot Her Dead.” Washington Post, July 31, 2024. https://www.washingtonpost.com/nation/2024/07/31/sonya-massey-killing-911-calls/.

Police Staff. “Former Ill. Deputy on Trial for Murder Testifies about Fatal OIS of Sonya Massey.” Police1, December 12, 2025. https://www.police1.com/legal/former-ill-deputy-on-trial-for-murder-testifies-about-fatal-ois-of-sonya-massey/.

Sanchez, Ray. “Former Illinois Deputy Found Guilty in Sonya Massey’s Killing.” CNN, October 29, 2025. https://www.cnn.com/2025/10/29/us/sonya-massey-verdict-deputy-guilty.

Sangamon County Sheriff’s Office. “Sonya Massey Information.” Sangamon County Government. Accessed December 13, 2025. https://sangamonil.gov/departments/s-z/sheriff/sonya-massey-information.

Stinson, Philip M. “On-Duty Shootings: Police Officers Charged with Murder or Manslaughter.” Police Integrity Lost: A Study of Law Enforcement Officers Arrested. Bowling Green State University, 2016. https://www.bgsu.edu/content/dam/BGSU/health-and-human-services/document/Criminal-Justice-Program/policeintegritylostresearch/-9-On-Duty-Shootings-Police-Officers-Charged-with-Murder-or-Manslaughter.pdf.

Yeagle, Patrick. “Sean Grayson Murder Trial Update: Sonya Massey Opening Arguments, Testimony Recap First Day.” The State Journal-Register, October 23, 2025. https://www.sj-r.com/story/news/politics/courts/2025/10/23/sean-grayson-murder-trial-update-sonya-massey-opening-arguments-testimony-recap-first-day/86836288007/.

Parlay Players: FBI Investigates NBA Personnel in Sports Betting Conspiracy

By: Yoon Choi
Edited By: Brooke Sharp and Eleanor Bergstein

Contextualization 

On October 23, an indictment in the U.S. District Court for the Eastern District of New York in Brooklyn charged six defendants in a widespread money laundering case involving National Basketball Association (NBA) players and coaches to profit from illegal sports betting. Under this investigation, the FBI arrested six former and current NBA players who allegedly provided insider information on professional games and purposefully manipulated in-game results to benefit the defendants. Among those arrested, notable individuals included Miami Heat guard Terry Rozier, Portland Trail Blazers coach Chauncey Billups, and former NBA player Damon Jones [1]. 

This scheme is closely related to a larger FBI investigation on illegal gambling with significant ties to mobs and mafia groups in New York. The case has grown significantly in size over its approximately 6-year investigation, initially starting as illegal poker games with cheating technologies. Some of these fraudulent mechanisms included a shuffling machine that rigged decks, and a “chip tray analyser” that read cards using secret cameras. The most recent indictment (including transactions from the NBA betting scheme) stated a massive array of damages, which demonstrated its expansive extent: a total of $7 million in losses, the arrest of 31 people across 11 states, and the alleged involvement of three major mafia families (Gambinos, Bonnanos, and Genoveses) [2]. 

NBA’s Response 

There was a diverse array of responses to this news from the NBA, both among the association itself and its players. After the press release, the NBA sent a memo to all 30 member teams, calling for a reassessment of the league’s gambling policies and its regulations for their players. The league officially stated that it is looking for improved strategies to regulate integrity within the association, experimenting with artificial intelligence-driven programs and other statistical tools. Billups and Rozier were both put on leave by the NBA following their arrest, and have not returned [3]. Billups and Rozier have been charged with two separate indictments, with the former being accused of being involved with the poker scheme and the latter for performance manipulation. 

NBA players, staff, and media were all shocked by the news that broke in the midst of opening-week for the 2025-26 season, warranting a variety of responses. Many of those with personal ties to the convicted individuals seemingly avoided comments on whether they were aware of the situation, mainly only stating their best wishes for Billups and Rozier as they went through legal proceedings. Miami Heat head coach Erik Spoelstra stated, “[Rozier] is somebody who is very dear to all of us. He has had a real positive impact on our locker room, on staff and players alike.” Similarly when asked about fellow head coach Chauncey Billups, Detroit Pistons’ JB Bickerstaff answered, “[I] know his family well. So you know, I know he's going through it. I know it's a difficult time for him, but all of us as friends and coaches are there for him.” Current players who shared close relationships like Heat forward and captain Bam Adebayo also publicly claimed the team is in “full support” of Rozier [4]. 

Other NBA personalities have reserved their words for the specific individuals involved in the case, but have addressed the severity of sports gambling in the league and the implications it brings upon the integrity of the game. With the NBA exponentially increasing as a business, players like Jaylen Brown (Boston Celtics) and Nikola Vucevic (Chicago Bulls) have expressed concern about the negativity that sports betting places on players and protecting them from such criticism [4]. 

Public Reaction 

The public expressed much greater dissent for the scandal than those directly involved in the association. Many negative comments were focused on the allegations against Terry Rozier, who was accused of faking injuries and playing poorly on multiple occasions to prop sports bets in the conspirators’ favor. Fans took to various social media platforms, like X and Instagram, to express their resentment. The gambling scandal also sparked a micro-trend among the social media space of NBA fans, in which users started to falsely identify as NBA personalities and admit involvement in gambling, thereby expressing their dislike for the individual and jokingly “attempting” to ruin their careers [5]. 

Future Implications 

This is not the first time that the NBA has been faced with significant gambling scandals. Notably in 2024, an allegation against Jontay Porter, former Toronto Raptor forward, caused him to be banned from the NBA after being found guilty of manipulating in-game performance for sports betting [6]. Porter’s case was evidence that sports betting not only externally impacts the league, but exists within the association, raising doubts about the league’s integrity. 

In June 2025, former Detroit Pistons guard Malik Beasley was also placed under federal investigation for manipulating performance to increase betting profits. When this charge was dismissed, the NBA launched their own subsequent investigation into Beasley in September [7]. Despite alleged “full-cooperation,” this case caused significant harm to Beasley’s career; the Detroit Pistons did not re-sign him in the free agency period due to the investigation, and he is still yet to be signed despite coming off a career year ranking second in three-pointers made in the 2024-25 season. 

Such diverse occurrences with sports-betting hold significant implications for not only the NBA, but sports leagues worldwide. As online-gambling continues to grow, both players and media have raised concerns about its impacts on the business side of sports, the mental health of athletes, the toxic fan environment, and the overall quality of the product that these leagues present. With this most recent federal case seemingly tied to wider criminal organizations, it raises greater concerns about the mysteries associated with the games industry and the movements that occur in the shadows that have direct monetary reverberations. As details continue to be released by the FBI, sports leagues will likely continue to crack down on integrity within their athletes and teams, aiming to produce an environment that draws viewership for profitability but also preserves the authenticity of the game. 

Notes: 

1. U.S. Department of Justice, “Current and Former National Basketball Association Players and Four Other Individuals Charged in Widespread Sports Betting and Money Laundering Conspiracy,” U.S. Attorney’s Office, Eastern District of New York, October 23, 2025, 

https://www.justice.gov/usao-edny/pr/current-and-former-national-basketball-association players-and-four-other-individuals. 

2. BBC News, “NBA gambling scandal explained,”, 

https://www.bbc.com/news/articles/c77zndkx5kpo. 

3. Shams Charania and David Purdum, “NBA memo addresses the need to assess ‘dire risks’ of gambling,” ESPN, October 27, 2025, 

https://www.espn.com/nba/story/_/id/46746697/nba-memo-addresses-need-assess-dire-ris ks-gambling. 

4. Michael C. Wright, “NBA gambling investigations: How players, coaches reacted to the news,” ESPN, October 27, 2025, 

https://www.espn.com/nba/story/_/id/46715098/nba-gambling-investigation-how-players coaches-reacted-news. 

5. Yahoo Sports, “Reactions: NBA rocked gambling scandal,” Sports.Yahoo.com, https://sports.yahoo.com/article/reactions-nba-rocked-gambling-scandal-180207946.html. 

6. David Purdum, “NBA bans Raptors’ Jontay Porter for gambling violations,” ESPN, April 17, 2024,

https://www.espn.com/nba/story/_/id/39962406/nba-bans-raptors-jontay-porter-gambling -violations. 

7. CBS Sports, “NBA launches investigation into gambling allegations against Malik Beasley amid federal probe,” September 10, 2025 , 

https://www.cbssports.com/nba/news/nba-launches-investigation-into-gambling-allegatio ns-against-malik-beasley-amid-federal-probe/. 

Bibliography: 

Charania, Shams, and David Purdum. 2025. “NBA Memo Addresses the Need to Assess ‘Dire Risks’ of Gambling - ESPN.” ESPN.com. ESPN. October 27, 2025. https://www.espn.com/nba/story/_/id/46746697/nba-memo-addresses-need-assess-dire-ris ks-gambling. 

Epstein, Kayla. 2025. “How FBI’s Gambling Case Highlights Mafia’s Changing Tactics.” BBC, October 23, 2025. https://www.bbc.com/news/articles/c77zndkx5kpo. 

ESPN. 2025. “NBA Gambling Investigations: How Players, Coaches Reacted to the News - ESPN.” ESPN.com. ESPN. October 27, 2025. 

https://www.espn.com/nba/story/_/id/46715098/nba-gambling-investigation-how-players coaches-reacted-news. 

Kalland, Robby. 2025. “NBA Launches Investigation into Gambling Allegations against Malik Beasley amid Federal Probe.” CBS Sports. 2025. 

https://www.cbssports.com/nba/news/nba-launches-investigation-into-gambling-allegatio ns-against-malik-beasley-amid-federal-probe/. 

Purdum, David. 2024. “NBA Bans Raptors’ Porter for Gambling Violations.” ESPN.com. April 17, 2024. 

https://www.espn.com/nba/story/_/id/39962406/nba-bans-raptors-jontay-porter-gambling -violations. 

US Attorney's Office. 2025. “Current and Former National Basketball Association Players and Four Other Individuals Charged in Widespread Sports Betting and Money Laundering Conspiracy.” Justice.gov. October 23, 2025. 

https://www.justice.gov/usao-edny/pr/current-and-former-national-basketball-association players-and-four-other-individuals.

Wojton, Nick. 2025. “Social Media Erupts after NBA Gambling Scandal Involving Chauncey Billups, Terry Rozier.” Yahoo Sports. October 23, 2025. https://sports.yahoo.com/article/reactions-nba-rocked-gambling-scandal-180207946.html.

The Peace on the Korean Peninsula Act: A Path to Ending a 70-Year Deadlock

By: Alan Hunchan Jeong

Although active fighting ended in 1953, the Korean War technically never concluded. The 1950–1953 conflict ended with an Armistice Agreement rather than a formal peace treaty, leaving the United States, South Korea, and North Korea still, in legal terms, at war. Most notably, South Korea requires every male citizen – many of whom can be easily encountered on U.S. college campuses – to serve in the military, highlighting the seriousness and urgency of geopolitical tensions in a divided nation amid the unresolved war. The region has been in a protracted state of limbo due to decades of hostilities and diplomatic setbacks.

To promote a peaceful resolution of the issues on the Korean Peninsula, Representative Brad Sherman (D-CA) has repeatedly introduced the Peace on the Korean Peninsula Act since the 117th Congress. Congressman Sherman emphasizes that the ongoing conflict on the Korean Peninsula is not in the best interests of the United States or its citizens with familial ties in North and South Korea, stressing the urgent need for serious diplomatic efforts to establish peace in the region. [1] The measure calls for the promotion of dialogue and a binding peace agreement between the U.S., South Korea, and North Korea, as well as the reassessment of the current stringent restrictions on U.S. interaction with North Korea.

The bill outlines a set of initiatives aimed at promoting peace on the Korean Peninsula. To begin, the bill seeks to restore diplomacy between South Korea, North Korea, and the United States, with the goal of officially ending the Korean War and establishing U.S.-North Korea liaison offices in Washington and Pyongyang. [2] The legislation requires the U.S. Department of State to submit a report to Congress outlining “a clear roadmap for achieving permanent peace agreement on the Korean Peninsula;” this report would include diplomatic strategies and recommendations for advancing U.S. engagement with both North Korea and South Korea to reach a “binding peace agreement constituting a formal and final end to the state of war between North Korea, South Korea, and the United States.” [3] By providing a framework for dialogue and permanent peace, the bill seeks to reinvigorate diplomatic efforts for engagement with North Korea that have largely stalled since the breakdown of the 2019 U.S.-North Korea talks in Hanoi, Vietnam. The failed attempt of the U.S.-North Korea Hanoi Summit reinforces the need for a detailed framework on how to approach North Korea. The backdrop for improving relations still exists, however, as the U.S.-North Korea joint statement signed in Singapore in 2018 included an agreement to “establish new U.S.-DPRK relations in accordance with the desire of the peoples of the two countries for peace and prosperity.” [4] A binding peace agreement and the respective liaison offices would not only enhance U.S.-North Korea relations by facilitating engagement that serves U.S. national interests but also advance greater humanitarian causes.

A second provision of the bill calls for a review of the travel restrictions currently in place for U.S. nationals wishing to visit North Korea. [5] Since 2017, the U.S. government has enforced strict travel bans preventing Americans from visiting North Korea due to security concerns, particularly in light of the tragic case of Otto Warmbier, a U.S. college student who died after being detained by North Korean authorities. [6] While these restrictions were enacted for citizens’ safety, the bill recognizes the “compelling humanitarian considerations” to reunite U.S. citizens with family members left in North Korea, as around 100,000 Americans have relatives there – at least to allow them to attend a funeral, burial, or commemoration of their loved ones. [7]

Despite its grand initiatives, the bill confronts substantial challenges. Opponents argue that the legislation seems premature and could pose serious security risks to South Korea, as it could result in the withdrawal of U.S. troops stationed there, the weakening of the U.S.-ROK alliance, the dissolution of the United Nations Command, and the lifting of sanctions on North Korea without ensuring its denuclearization. [8] To address critics’ concerns that the bill’s enactment could lead to the withdrawal of U.S. troops from South Korea, the updated version of the legislation introduced in the 118th Congress includes Section 6, Rule of Construction: “Nothing in this Act may be construed to affect the status of United States Armed Forces stationed in South Korea or any other foreign country.” [9] Accordingly, Seoul’s stances on engagement with North Korea and a peace agreement are determining factors. While past South Korean administrations – particularly under Presidents Kim Dae-jung, Roh Moo-hyun, and Moon Jae-in – actively pursued engagement with North Korea through several summit meetings with its leaders, the current conservative administration has taken a hawkish stance on North Korea. [10]

However, it is important to recognize that the kind of engagement the bill calls for with North Korea does not necessarily mean appeasement. Instead, it provides opportunities to manage tensions, lower the risk of contingencies, and gradually build trust between opposing parties. A realpolitik example is the rapprochement between the U.S. and the People’s Republic of China during the Sino-Soviet split in the Cold War, which may have aided U.S. national interests by hastening the eventual decline of the Soviet Union. Policymakers must carefully navigate the broader geopolitical landscape to discover creative diplomatic pathways that could boost overall security.

As the bill continues to progress through Congress – it already enjoys bipartisan backing, with 52 cosponsors by the end of the 118th Congress – its success will hinge on public support for engagement over confrontation. [11] If the Act becomes law, it will represent a major step toward peace, not only on the Korean Peninsula but across East Asia and the broader Indo-Pacific. It would be a reminder that careful diplomacy and patient engagement can still work when it comes to addressing long-standing regional challenges, such as the ones on the Korean Peninsula and in other notable places, such as the Taiwan Strait.

NOTES:

1. “Congressman Brad Sherman Leads Colleagues in Re-Introducing the Peace on the Korean Peninsula Act,” Congressman Brad Sherman, March 1, 2023, accessed February 15, 2025, https://sherman.house.gov/media-center/press-releases/congressman-brad-sherman-leads-colleagues-in-re-introducing-the-peace-on.

2. “Text - H.R.1369 - 118th Congress (2023-2024): Peace on the Korean Peninsula Act,” Congress.gov, March 3, 2023, accessed February 15, 2025, https://www.congress.gov/bill/118th-congress/house-bill/1369/text.

3. Ibid.

4. Ibid.

5. Ibid.

6. Department of State, “United States Passports Invalid for Travel To, In, or through the Democratic People’s Republic of Korea (DPRK),” Federal Register, August 8, 2024, accessed February 15, 2025, https://www.federalregister.gov/documents/2024/08/08/2024-17519/united-states-passports-invalid-for-travel-to-in-or-through-the-democratic-peoples-republic-of-korea.

7. “Text - H.R.1369.”

8. Hyeon-seok Gang, “[bareondae] ‘hanbando pyeonghwabeobane’un sigisangjo [[Speakers’ Corner] The ‘Peace on the Korean Peninsula Act’ Is Premature],” Koreatimes.com, February 12, 2025, accessed February 15, 2025, http://www.koreatimes.com/article/20250212/1551631.

9. “Text - H.R.1369.”

10. Gagan Hitkari, “Why South Korea Needs to Reassess Its Hardline Stance against Pyongyang,” South China Morning Post, November 10, 2024, accessed February 15, 2025, https://www.scmp.com/opinion/asia-opinion/article/3285856/why-south-korea-needs-reassess-its-hardline-stance-against-pyongyang.

11. “Cosponsors - H.R.1369 - 118th Congress (2023-2024): Peace on the Korean Peninsula Act,” Congress.gov, March 3, 2023, accessed February 15, 2025, https://www.congress.gov/bill/118th-congress/house-bill/1369/cosponsors.

BIBLIOGRAPHY:

Congress.gov. “Cosponsors - H.R.1369 - 118th Congress (2023-2024): Peace on the Korean Peninsula Act,” March 3, 2023, accessed February 15, 2025. https://www.congress.gov/bill/118th-congress/house-bill/1369/cosponsors.

Congress.gov. “Text - H.R.1369 - 118th Congress (2023-2024): Peace on the Korean Peninsula Act,” March 3, 2023, accessed February 15, 2025. https://www.congress.gov/bill/118th-congress/house-bill/1369/text.

Congressman Brad Sherman. “Congressman Brad Sherman Leads Colleagues in Re-Introducing the Peace on the Korean Peninsula Act,” March 1, 2023, accessed February 15, 2025. https://sherman.house.gov/media-center/press-releases/congressman-brad-sherman-leads-colleagues-in-re-introducing-the-peace-on.

Department of State. “United States Passports Invalid for Travel To, In, or through the Democratic People’s Republic of Korea (DPRK).” Federal Register, August 8, 2024, accessed February 15, 2025. https://www.federalregister.gov/documents/2024/08/08/2024-17519/united-states-passports-invalid-for-travel-to-in-or-through-the-democratic-peoples-republic-of-korea.

Gang, Hyeon-seok. “[bareondae] ‘hanbando pyeonghwabeobane’un sigisangjo [[Speakers’ Corner] The ‘Peace on the Korean Peninsula Act’ Is Premature],” Koreatimes.com, February 12, 2025, accessed February 15, 2025. http://www.koreatimes.com/article/20250212/1551631.

The Legal Battles of the Federal Funding Freeze

By: David Rodriguez
Edited by: Sam Yip and Anna Dellit

Following the multiple executive orders of President Donald Trump, the Office of Management and Budget (OMB) issued a memorandum titled M-25-13, directing all federal agencies to temporarily pause federal financial assistance involving nongovernmental organizations and issues, such as climate change and diversity, equity, and inclusion. [1] This action aimed to review and match federal government spending with the Trump administration's agenda. [2] The broad scope of the memo sparked uncertainty among states, schools, and organizations that receive trillions of dollars from the federal government. [3] Later, the Trump administration clarified that direct assistance programs such as food stamps, Medicare, and student loans would not be affected, but provided an uncertain stance at times regarding programs like Medicare. [4] 

This prompted states and nongovernmental organizations to turn to the courts and launch lawsuits against the Trump administration. On January 28th, U.S. District Judge Loren L. AliKhan from the District of Columbia issued an administrative stay until Monday, February 3, blocking the memo moments before it was said to take into effect. [5] This action arose from an emergency hearing involving nonprofit groups that receive federal assistance. [6]

The Office of Management and Budget then rescinded M-25-13 the next day. According to White House Press Secretary Karoline Leavitt, these efforts were to end both the confusion that news outlets and courts have caused, while also ending all legal challenges. [7] Leavitt also states that eliminating the M-25-13 was not a rescission of the efforts to administer a funding freeze. [8] This prompted U.S. District Court Chief Judge John J. McConnell to issue a temporary restraining order on January 31. [9] This legal challenge was brought by 22 states and the District of Columbia in a Rhode Island Federal Courthouse. [10] The temporary restraining order prohibited the Trump administration from freezing any federal grant and loan payments. [11] Chief Judge McConnell called the funding freeze unconstitutional due to a violation of the separation of powers where the executive exercised authority reserved for congress. [12] There is no federal law that would allow the executive branch to implement such an order by itself. [13] Chief Judge McConnell also sees this federal freeze as a mechanism that causes harm to states like California’s relief efforts with wildfires. [14]

Similar conclusions were made on February 3, when U.S. District Judge Loren L. AliKhan held a hearing on the motion for a temporary restraining order. Judge AliKhan justified the granting of this temporary restraining order by displaying how a nonprofit that assists disabled West Virginians living in their own homes still could not access funds that they receive from the Department of Health and Human Services. [15] This resulted in the layoff of one employee and has led to services being reduced. [16] It is clear that the Trump administration did not obey Judge AliKhan’s original order and with the memo implicating as much as three trillion dollars in assistance [17], action needed to be taken. Judge AliKhan highlights similar concerns as Chief Judge McConnell regarding constitutionality. Judge Alikhan states that this memo tried to snatch the power of the purse from the only branch that is entitled to it, which is Congress. [18]

Throughout these legal challenges, states and nongovernmental agencies face real concern. The Trump administration crafted a 51-page spreadsheet that was sent out to federal agencies, highlighting programs that would be under review. [19] The programs ranged from special education to pool safety. [20] Many states had trouble accessing funds through Medicaid and online portals used to access federal assistance were temporarily taken offline. [21] Other organizations that involved services like childcare in Wisconsin had issues accessing federal funding. [22] Whole cities like Prichard, Alabama had concerns about federal infrastructure funding that would be critical to fix their drinking water system, but now was in jeopardy. [23] 

In February, Judge McConnell was notified of multiple Democratic-led states still having trouble accessing billions of dollars even after the issuance of the temporary restraining order. [24] He believes that this was cause for states to have a “rightful concern” while making it clear that the court was ready to enforce the temporary restraining order. [25] During the preliminary injunction hearing, Judge McConnell reasserted the unconstitutionality of the federal funding freeze stating that with this order, the executive would put itself above Congress. [26] Depending on the state, federal funding can account for around 18 to 50 percent of the state’s budget. [27] A federal funding freeze or cut means states must make up for this sum, causing hardships for states with stressed budgets. [28]

While the courts are addressing this attempt at a federal funding freeze, there are other mechanisms targeting state and federally funded programs. At the agency level, such as in the Department of Agriculture, more than one billion dollars of additional funding provided by the Biden administration has been halted. [29] This decision will impact the Local Food for Schools program and the Local Food Purchase program which provides funds to schools and food assistance organizations. [30] While the Department of Agriculture unfroze the existing funding agreements for the Local Food Purchase program, the following round of funding will not occur. [31] Additionally, Elon Musk and the Department of Government Efficiency vow to cut one trillion dollars in overall federal spending. [32]

On the congressional side, a continuing resolution bill has passed the Senate which will fund the government until September 30 with a thirteen billion dollar cut in nondefense spending impacting earmarks for items such as higher education. [33] Additionally, many programs in the continuing resolution do not have established funding levels such as Pell Grants allowing the Trump administration to have the ability and ask Congress to withdraw funds. [34] As federal funds become a continuous target, ongoing legal battles about freezes or cuts become vital to follow.

NOTES:

1. National Council of Nonprofits et al v. Office of Management and Budget et al, 1:25-cv-00239, D.D.C, 1 (2025) 

2. Lindsay Whitehurst, “Judge in Nation’s Capital Extends Block on Trump Administration Federal Funding Freeze,” The Associated Press News, February 3, 2025, https://apnews.com/article/trump-federal-grants-loans-funding-freeze-court-1bc457d8e333dd8a8f374572ea33927. AP 1

3. Chris Megerian and Lindsay Whitehurst, “Federal Judge Temporarily Blocks Trump Administration Freeze on Federal Grants and Loans,” The Associated Press News, The Associated Press, January 29, 2025, https://apnews.com/article/donald-trump-pause-federal-grants-aid-f9948b9996c0ca971f0065fac85737ce. 

4. Megerian et al., “Federal Judge Temporarily Blocks Trump Administration Freeze on Federal Grants and Loans”

5. Chris Megerian, Zeke Miller, and Lisa Mascaro, “Trump White House Rescinds Memo Freezing Federal Money After Widespread Confusion,” The Associated Press News, January 29, 2025, https://apnews.com/article/donald-trump-pause-federal-grants-aid-6d41961940585544fa43a3f66550e7be. 

6. Merergian et al., “Trump White House Rescinds Memo Freezing Federal Money After Widespread Confusion”

7. Merergian et al., “Trump White House Rescinds Memo Freezing Federal Money After Widespread Confusion”

8. Jordan Fischer, “‘No Legal Authority’ | JudgeBlocks Federal Funding Freeze in 22 States and DC,” WUSA9, January 31, 2025, https://www.wusa9.com/article/news/legal/judge-mcconnell-blocks-federal-funding-freeze-in-22-states-and-dc-omb-office-of-management-and-budget/65-a69062f4-48ae-463e-972d-d43b40287d69.

9. Fischer, “‘No Legal Authority’ | JudgeBlocks Federal Funding Freeze in 22 States and DC”

10. Fischer, “‘No Legal Authority’ | JudgeBlocks Federal Funding Freeze in 22 States and DC”

11. Fischer, “‘No Legal Authority’ | JudgeBlocks Federal Funding Freeze in 22 States and DC”

12. Fischer, “‘No Legal Authority’ | JudgeBlocks Federal Funding Freeze in 22 States and DC”

13. Fischer, “‘No Legal Authority’ | JudgeBlocks Federal Funding Freeze in 22 States and DC”

14. Fischer, “‘No Legal Authority’ | JudgeBlocks Federal Funding Freeze in 22 States and DC”

15.  Maureen Groppe, “Judge Extends Pause on Trump Funding Freeze After Finding Administration Has Not Complied,” USA Today, February 3, 2025, https://www.usatoday.com/story/news/politics/2025/02/03/judge-trump-administration-funding-freeze/78180951007/.

16. Groppe, “Judge Extends Pause on Trump Funding Freeze After Finding Administration Has Not Complied”

17. NCN et al v. OMB et al, 24.

18. NCN et al v. OMB et al, 25

19. Megerian et al., “Federal Judge Temporarily Blocks Trump Administration Freeze on Federal Grants and Loans”

20. Megerian et al., “Federal Judge Temporarily Blocks Trump Administration Freeze on Federal Grants and Loans”

21. Alys Davies, Kayla Epstein, and Max Matza,“White House Rescinds Memo on Freezing Federal Grants and Loans,” BBC, January 29, 2025, https://www.bbc.com/news/articles/cyv48540n4po.

22. Whitehurst, “Judge in Nation’s Capital Extends Block on Trump Administration Federal Funding Freeze”

23. Megerian et al., “Federal Judge Temporarily Blocks Trump Administration Freeze on Federal Grants and Loans”

24. Nate Raymond, “US States Tell Judge Trump Not Fully Following Order Blocking Funding Freeze,” Reuters, February 6, 2025, https://www.reuters.com/legal/us-states-tell-judge-trump-not-fully-following-order-blocking-funding-freeze-2025-02-06/.

25. Raymond, “US States Tell Judge Trump Not Fully Following Order Blocking Funding Freeze”

26. Elena Moore, “A Second Federal Judge Has Ruled to Block the Trump Administration’s Spending Freeze,” NPR, March 6, 2025 https://www.npr.org/2025/03/06/nx-s1-5312069/trump-federal-funding-freeze-court-order.  

27. Kennedy Andara and Mimla Wardak, “The Consequences of a Federal Funding Freeze in the States,” Center for American Progress, February 6, 2025, https://www.americanprogress.org/article/the-consequences-of-a-federal-funding-freeze-in-the-states/.

28. Andara et al., “The Consequences of a Federal Funding Freeze in the States.”

29. Marcia Brown, “USDA Cancels $1B in Local Food Purchasing for Schools, Food Banks,” Politico, March 10, 2025 https://www.politico.com/news/2025/03/10/usda-cancels-local-food-purchasing-for-schools-food-banks-00222796

30. Brown, “USDA Cancels $1B in Local Food Purchasing for Schools, Food Banks”

31. Brown, “USDA Cancels $1B in Local Food Purchasing for Schools, Food Banks”

32. Nathan Layne and Costas Pitas, “Musk Says he Will Finish Most of $1 Trillion Federal Cost Within Weeks,” Reuters, March 27, 2025 https://www.reuters.com/world/us/musk-says-1-trillion-us-spending-cuts-possible-without-touching-services-2025-03-27/

33. Maria Carrasco, “Senate Passes Federal Spending Bill, Averting Government Shutdown,” National Association of Student Financial Aid Administrators, March 17, 2025 https://www.nasfaa.org/news-item/35850/Senate_Passes_Federal_Spending_Bill_Averting_Government_Shutdown

34. Carrasco, “Senate Passes Federal Spending Bill, Averting Government Shutdown”
    

BIBLIOGRAPHY:

Andara, Kennedy and Mimla Wardak. “The Consequences of a Federal Funding Freeze in the States” Center for American Progress, February 6, 2025. https://www.americanprogress.org/article/the-consequences-of-a-federal-funding-freeze-in-the-states/.

Brown, Marcia. “USDA Cancels $1B in Local Food Purchasing for Schools, Food Banks” Politico, March 10, 2025. https://www.politico.com/news/2025/03/10/usda-cancels-local-food-purchasing-for-schools-food-banks-00222796

Carrasco, Maria. “Senate Passes Federal Spending Bill, Averting Government Shutdown” National Association of Student Financial Aid Administrators, March 17, 2025. https://www.nasfaa.org/news-item/35850/Senate_Passes_Federal_Spending_Bill_Averting_Government_Shutdown

Davies, Alys, Epstein, Kayla, and Max Matza. “White House Rescinds Memo on Freezing Federal Grants and Loans” BBC, January 29, 2025. https://www.bbc.com/news/articles/cyv48540n4po.

Fischer, Jordan. “‘No Legal Authority’ | JudgeBlocks Federal Funding Freeze in 22 States and DC” WUSA9, January 31, 2025. https://www.wusa9.com/article/news/legal/judge-mcconnell-blocks-federal-funding-freeze-in-22-states-and-dc-omb-office-of-management-and-budget/65-a69062f4-48ae-463e-972d-d43b40287d69.

Groppe, Maureen. “Judge Extends Pause on Trump Funding Freeze After Finding Administration Has Not Complied” USA Today, February 3, 2025. https://www.usatoday.com/story/news/politics/2025/02/03/judge-trump-administration-funding-freeze/78180951007/.

Layne, Nathan and Costas Pitas. “Musk Says he Will Finish Most of $1 Trillion Federal Cost Within Weeks” Reuters, March 27, 2025. https://www.reuters.com/world/us/musk-says-1-trillion-us-spending-cuts-possible-without-touching-services-2025-03-27/

Megerian, Chris, Miller, Zeke, and Lisa Mascaro. “Trump White House Rescinds Memo Freezing Federal Money After Widespread Confusion” The Associated Press News, January 29, 2025. https://apnews.com/article/donald-trump-pause-federal-grants-aid-6d41961940585544fa43a3f66550e7be.

Megerian, Chris, and Lindsay Whitehurst. “Federal Judge Temporarily Blocks Trump Administration Freeze on Federal Grants and Loans” The Associated Press News, January 29, 2025. https://apnews.com/article/donald-trump-pause-federal-grants-aid-f9948b9996c0ca971f0065fac85737ce.

Moore, Elena. “A Second Federal Judge Has Ruled to Block the Trump Administration’s Spending Freeze” NPR, March 6, 2025. https://www.npr.org/2025/03/06/nx-s1-5312069/trump-federal-funding-freeze-court-order

National Council of Nonprofits et al v. Office of Management and Budget et al, 1:25-cv-00239, D.D.C, 1 (2025)

Raymond, Nate. “US States Tell Judge Trump Not Fully Following Order Blocking Funding Freeze” Reuters, February 6, 2025. https://www.reuters.com/legal/us-states-tell-judge-trump-not-fully-following-order-blocking-funding-freeze-2025-02-06/.

Whitehurst, Lindsay. “Judge in Nation’s Capital Extends Block on Trump Administration Federal Funding Freeze” The Associated Press News, February 3, 2025. https://apnews.com/article/trump-federal-grants-loans-funding-freeze-court-1bc457d8e333dd8a8f374572ea33927.c