DOJ’s Request for Sensitive Data from Minnesota Builds on the Trump Administration’s Unprecedented Effort to Consolidate Personal Data Across the Federal Government

Introduction

In the wake of ICE’s recent violence against Minnesotans, the Department of Justice (DOJ) sent a letter to Governor Tim Walz reissuing demands to the state for complete access to Medicaid, SNAP, and voter roll data. The letter to Governor Walz garnered significant attention, and for many Americans it was the first time that they learned of the federal government’s attempts to access personal data held by state governments — sensitive information that has historically never been shared with the federal government. As CDT stated in response to the events in Minnesota, DOJ’s demand was “an unambiguous attempt to strongarm states into giving up more data about their residents and fits with a longer pattern of efforts to weaponize claims of fraud and waste to hoover up additional information about beneficiaries and disenfranchise eligible voters.” 

CDT’s civic technology team has actively worked on the federal government’s attempts to access data collected by states to administer benefits programs like Medicaid and SNAP for the past year. This blog will recap what has happened since this Administration took office, why people should care about the federal government consolidating their personal information, and what’s different about what we’re seeing play out in Minnesota.

Recap of Past Year: Rapid Erosion of Long-Stand Privacy Norms

The DOJ’s demand for this sensitive information from Minnesota’s state government is not new, instead building on a year-long effort by the federal government to dramatically expand access to and consolidate federal and state administrative data. In fact, the letter reiterates demands for sensitive information already made by multiple federal agencies following the Trump Administration’s Executive Order on Eliminating Information Silos. In May, the U.S. Department of Agriculture (USDA) sent a letter to state agencies demanding access to a host of sensitive information about every SNAP applicant and recipient since 2020, including their names, Social Security numbers, and addresses. In July, the Centers for Medicare & Medicaid Services gave ICE access to the personal information of nearly 80 million Medicaid recipients, including Social Security numbers and ethnicities.

These unprecedented data demands have resulted in a slate of lawsuits challenging the legality of the federal government’s collection, handling, and use of highly sensitive personal information. Such efforts to push back on federal data requests in court include four lawsuits specifically challenging attempts to access state administrative data, including three focused on access to SNAP data and one on Medicaid data. These suits draw on a number of long-standing legal protections that apply both to the federal government’s requests for sensitive information and to a state’s provision of such information to the federal government. Although many of these lawsuits are still moving through the courts, they highlight the significant uncertainty around the legality of the federal government’s ongoing efforts to access and consolidate administrative data.

Why People Should Care About the Federal Government Consolidating Their Personal Data

The DOJ’s letter to Minnesota officials is not only a dangerous and stark escalation of the Trump Administration’s ongoing efforts to consolidate and potentially misuse individuals’ sensitive information, but misrepresents the very nature of the federal government’s attempt to access this information. This effort should be a call to all of us to take seriously the threat that the Trump Administration’s actions pose to data privacy and our fundamental rights.

Reason #1: The Pairing of Consolidated Personal Data with the Wide-Reaching Power and Force of the Federal Government is an Unparalleled Threat 

Providing the government of the world’s most powerful country with unfettered access to consolidated data exposes state governments and their residents to unique, unprecedented harms, including:

• Loss of federal funding and a chilling effect on lawful participation in crucial benefits programs;
• Mass surveillance and algorithmic profiling and targeting, which can lead to unfounded and discriminatory criminal and administrative investigations, including immigration enforcement efforts; and
• Threats of military intervention and ramped up immigration enforcement in response to a state’s refusal to provide data. 

The federal government’s past efforts to access state data often came with dubiously legal threats of rescinding federal funding if states refused to turn over large amounts of sensitive personal information. Current events suggest a clear escalation of intimidation and threats for compliance, as the DOJ sent a letter reiterating its data demands mere days after the killing of a Minnesotan by federal law enforcement amidst a period of heightened unrest in Minneapolis. 

Reason #2: Turning Over Complete Access to State Data Puts Data Privacy at Greater Risk

Sharing and consolidating data from state benefits programs significantly threatens the privacy and security of individuals’ information. The information collected by state agencies includes extremely sensitive data that may not be captured in existing federal databases. For example, this can include:

• Information related to incarceration (date, jurisdiction of jail, and expected release date);
• Child or spousal support documents and the names of absent parents;
• Proof of relationship to family members, like birth certificates; and
• Reason for separation from employer.

When more information is stored in one place, it introduces a single point of failure and becomes a larger target for bad actors, increasing risks of data breaches and the misuse of personal data. Many government agencies already struggle to effectively manage the safety and security of sensitive information, and capitulating to these demands will only worsen this environment.

Reason #3: Open-Ended Access to Beneficiary Data Could Actually Worsen Fraud

In addition to putting the basic privacy of all Minnesotans at risk, this kind of data sharing could increase fraud and prevent eligible beneficiaries from accessing needed programs and services. The heightened privacy risks introduced by sharing and consolidating large amounts of sensitive information make it easier for bad actors, fraudsters, and hackers to access sensitive information about beneficiaries and potentially commit benefits fraud. 

Moreover, these requests distract from and undermine serious efforts that are already underway to prevent fraud in state programs. In fact, Minnesota launched a state-wide effort to combat fraud in benefits programs last September, including directives to publish information about program integrity and launch coordinated enforcement efforts.

What’s Different About What We’re Seeing Play Out in Minnesota?

The DOJ’s recent effort to pressure Minnesota to turn over sensitive information about state residents is a reckless attempt to further weaponize administrative data and significantly raises the stakes for states as they examine the legality of the requests that they receive from the federal government. While prior federal requests for state data have come from the federal agency with corresponding jurisdiction over specific programs (e.g., USDA made the initial request for state SNAP data), this most recent demand comes directly from DOJ, in the wake of DOJ’s recently established national fraud enforcement division. 

Most significantly, DOJ’s reiterated demands to the state of Minnesota dramatically escalate what this kind of request means, tying efforts to access state data to threats of immigration enforcement activity that has led to violence. While the DOJ’s letter does not explicitly make that link, state lawmakers have characterized the issuance of the letter as a “ransom note,” noting the extraordinary move to reiterate the demand for state data amidst significant violence perpetrated against Minnesotans. In response to the DOJ’s request, a coalition of 22 state attorneys general sent a letter to Attorney General Pam Bondi and Secretary of Homeland Security Kristi Noem rejecting their attempt to use violence and intimidation to force Minnesota to turn over “broad access to sensitive records based on unsupported assertions.” Since issuing the request, however, the DOJ has refuted claims that Minnesota’s willingness to share this information would end ICE’s deployment in the state, giving no guarantee that information-sharing would result in ICE leaving nor protect the lives of Minnesotans.

Conclusion

CDT will continue to engage on this issue and support strong safeguards for personal data, especially in the face of continued federal overreach. As part of this work, we recently:

• Joined allied organizations in condemning the actions of ICE and demanding that Congress reject further funding for ICE and CBP without meaningful oversight and control;
• Published an analysis of 2025 state legislative efforts to address changes in federal access to state administrative data;
• Released a series of four explainers on issues related to government data privacy, including voter data, state administrative data, immigration and government data, and DOGE’s impact on privacy protections;   
• Published a guide to state public benefits administrators on complying with existing privacy protections amidst an evolving immigration landscape;
• Released an analysis of data consolidation efforts in other democratic countries to highlight the potential harms that might arise from ongoing efforts to amass and centralize data within the federal government; 
• Joined allied organizations in urging the Department of Labor to withdraw a proposed rule that would require states to provide sensitive unemployment insurance information to the federal government; and
• Submitted comments to Representative Lori Trahan about reforming the Privacy Act of 1974 to address advances in technology and emerging threats to federal government data privacy.

As this landscape continues to evolve, CDT remains steadfast in our commitment to advocate for strong protections for sensitive information held by government agencies across the country.