Trump lost more than two-thirds of the lawsuits filed against his rules in his first term. His win rate of 31% was lower than that of the three administrations prior, according to an analysis by the Institute of Policy Integrity at the New York University School of Law.

Newsom and California are frequently the target of Trump’s ire. Some of his most memorable criticisms of the state have been over how it manages its wildlands in the face of wildfire risk. In his first term, Trump suggested California should be “raking” their forests to clean up dead brush and trees.