Maryland has initiated legal action against the Trump administration, challenging the decision to alter a previously sanctioned relocation plan for the FBI headquarters.

In July 2025, the FBI revealed its intention to halt the longstanding initiative aimed at moving its main offices from Washington, D.C., to a site in either Maryland or Virginia. Contrary to the original plan, the FBI opted to retain its presence in the capital, with plans to occupy the Ronald Reagan Building.

This relocation initiative began in 2014, steered by the General Services Administration (GSA) following a congressional directive. The process spanned several years, involving various legislative measures and a competitive bidding process among interested municipalities. In 2023, the GSA chose Greenbelt, Maryland, as the site for the ambitious project, which was projected to exceed $1 billion.

On Thursday, Maryland and Prince George’s County filed a 30-page legal complaint, asserting that the “sudden decision” made by the FBI and GSA contravenes multiple “statutory directives” and breaches the Administrative Procedure Act (APA), the federal law regulating agency conduct.

According to the lawsuit, the plaintiffs contend that the revised plan represents an attempt “to unlawfully undermine a multiyear collaborative effort.”

The protracted process plays a central role in the legal challenge:

Throughout the selection process for the FBI headquarters, Maryland and Prince George’s County leaders joined in a coordinated bipartisan effort to ensure the federal government used a fair, transparent, and lawful process to select a site for the new headquarters, and to provide relevant stakeholders with information to make a reasoned selection that supported the FBI’s security and mission needs. State and county leaders joined in this effort based on their expectation that securing the FBI headquarters in Prince George’s County would bring transformative benefits to the County and the State.

“We played by the rules,” Maryland Attorney General Anthony Brown said at a press conference announcing the litigation. “We won the project fairly and we will not let this administration steal jobs and opportunities from Prince George’s County and Maryland.”

And since the site was selected, Maryland and the county have been busy, the plaintiffs note.

“Maryland and Prince George’s County have made extensive preparations since the September 2023 selection,” the lawsuit goes on. “In 2025, Maryland enacted a law requiring the Governor to include at least $200 million in the annual budget for site redevelopment…[F]or fiscal year 2025, Prince George’s County approved $131 million in funding for activities in support of the FBI headquarters project.”

All those preparations, of course, have since been tossed to the wayside. But the plaintiffs say the process has gone on far too long — and influenced both the parties and the land in question in demonstrable ways — for the government to just walk away.

“The challenged decisions of the FBI and the GSA impair Maryland’s ability to negotiate for and ultimately obtain payment or other consideration in exchange for the easement or other rights to the property,” the complaint continues. “The challenged decisions of the FBI and the GSA also impair the market value of the parcel owned by Maryland, because a plan by the federal government to obtain rights to property necessarily increases the market value of that property.”

Beyond just an announcement, however, the Trump administration quickly moved to reallocate funds previously approved for the Greenbelt project to the Reagan Building project, the lawsuit notes.

The plaintiffs do not mince words about those actions.

“The FBI and the GSA have since taken or proposed to take further steps to divert funding,” the filing reads. “But these steps violate the law.”

To that end, the lawsuit accuses the FBI and GSA of violating multiple federal laws that created — and over successive years continued — the process of selecting the Greenbelt site. The lawsuit also says the agencies are in stark violation of a congressional funding bill that allocated over $1.1 billion for the Greenbelt headquarters.

The plaintiffs say the efforts to shift those funds over to construction at the Reagan Building are impermissible “reprogramming.”

“The decisions of the FBI and the GSA selecting the Ronald Reagan Building as the FBI headquarters site and the FBI’s decision to reprogram funds designated for the headquarters project have caused and will cause material and predictable harm to Maryland and Prince George’s County,” the lawsuit goes on.

Those arguments more or less dovetail with the claims essayed under the APA, specifically the argument that the midstream horse-jumping here is “arbitrary and capricious,” a term of art which refers to agency actions that go too far while simultaneously eschewing formal, mandatory processes.

Again, the filing at length:

[T]he FBI failed to acknowledge and address the prior selection plan and selection decision and the factual findings and reasoning underlying them. The FBI failed to consider important aspects of the problem, including the needs of the FBI, the costs and feasibility of the Ronald Reagan Building plan, and the statutory limitations applicable to the site selection and the funding provided by Congress for the headquarters project. The FBI also failed to consider the reliance interests of Maryland and Prince George’s County in the selection of Greenbelt.

The plaintiffs are asking the court to vacate the Reagan Building plan and to enjoin the FBI and GSA from moving forward with that plan.