Boston – The First Circuit Court of Appeals has rejected a Trump-Vance administration request to overturn a court order that is blocking the administration’s attempts to implement unlawful and unreasonable restrictions that seek to shift funding away from proven solutions to homelessness.
For years and through multiple presidential administrations, the Department of Housing and Urban Development’s (HUD) Continuum of Care (CoC) Program has helped provide the necessary resources for local governments and organizations to fund permanent housing projects for veterans, seniors, people with disabilities, and individuals and families with children experiencing homelessness. On November 13, 2025, however, without explanation, HUD rescinded the two-year notice of funding opportunity (NOFO) that should have governed FY 2025 awards and replaced it with one that threatens existing services, which could push nearly 200,000 Americans into homelessness. It then issued yet another new NOFO a month later. The new NOFO for FY 2025 upended the stability of the program required by law, and would have a devastating impact for communities, unhoused and previously unhoused children, youth, adults, and families, and the service providers who rely on federal funding to provide needed help.
A broad coalition of local governments and nonprofit organizations took legal action to stop the new NOFO in National Alliance to End Homelessness et al. v. HUD, and in December 2025, a federal judge granted preliminary relief, which temporarily blocks the administration’s attempts to implement the unlawful and unreasonable restrictions that seek to shift funding away from proven solutions to homelessness. Today’s decision maintains that block and confirms that Congress’s recent law requiring HUD to renew existing grants does not mean that HUD may implement the unlawful conditions.
The coalition behind the lawsuit includes the National Alliance to End Homelessness (NAEH), the National Low Income Housing Coalition (NLIHC), Crossroads Rhode Island, Youth Pride, Inc., as well as the County of Santa Clara, Calif., San Francisco, Calif., King County, Wash., Boston, Mass., Cambridge, Mass., Nashville, Tenn., and Tucson, Ariz.
The coalition released the following statement in response to the order:
“As the Trump-Vance administration continues to weaponize federal funding and attempts to hold hostage support for people experiencing homelessness – including families, seniors, veterans, and people with disabilities – we are relieved that the appeals court has left the order we earned late last year in place. We will continue to pursue this case and remain dedicated to protecting proven solutions to homelessness and the hundreds of thousands of people who rely on this vital support.”
Democracy Forward and the ACLU Foundation of Rhode Island represent the coalition of nonprofit organizations in the matter; the National Homelessness Law Center represents NAEH and NLIHC; Public Rights Project represents the cities of Boston, Cambridge, Nashville, and Tucson as well as King County; Santa Clara County and San Francisco are also plaintiffs. The Lawyers’ Committee for Rhode Island represents all plaintiffs.
Plaintiff and co-counsel quotes regarding the original filing are available here.
Read the court’s order here.