National Alliance to End Homelessness v. HUD

Public Rights Project, on behalf of local governments, filed a lawsuit challenging the Trump administration’s efforts to upend long-standing and effective policies that address homelessness. Public Rights Project and Democracy Forward are representing the plaintiffs in the case, alongside the National Homelessness Law Center.

The case focuses on the Continuum of Care (CoC) grant program administered by the U.S. Department of Housing and Urban Development (HUD). With a 2025 budget of $3.9 billion, it is the primary source of federal funding for addressing homelessness in the U.S. Local governments use CoC funding to keep people housed through permanent supportive housing, emergency shelter, street outreach, and services for people with disabilities and serious mental health needs.

In a recent grant notice, HUD reallocated funding away from long-term housing and introduced harmful requirements that CoCs would have to accept in order to receive funding. The changes prioritize approaches that have been proven less effective — such as requiring people who are homeless to address substance use issues before accessing housing — and it prioritizes CoCs that criminalize homelessness.

In addition, HUD threatens to reject CoC applicants that previously or currently adopted policies it views as “facilitating racial preferences,” despite prior applications requiring a plan for addressing racial equity. HUD also unlawfully excludes mental health conditions from the definition of disabilities.

If HUD cuts funding for long-term supportive housing, thousands of organizations across the country will close, displacing 170,000 people with disabilities and straining public services. 

Since the early 2000s, HUD has used the evidence-based Housing First approach, which prioritizes placing people who are homeless into housing as soon as possible. Then, they are offered treatment for substance abuse or mental health and provided other support. Research shows this approach helps people stay housed and makes communities safer, while also reducing the strain on local government resources. 

As we explain in the complaint, HUD’s actions violate the Constitution and parts of the Homeless Assistance Act. HUD also unlawfully issued the NOFO outside the required schedule and without legal justification.

More than $266 million is at stake for the local governments in the case, and the funding notice covers over $3.9 billion in federal funds. Public Rights Project represents Boston, Massachusetts; Cambridge, Massachusetts; King County, Washington; Nashville, Tennessee; and Tucson, Arizona. The other local government plaintiffs are San Francisco, California and Santa Clara, California.

Read the motion for a preliminary injunction.

Update:

On December 23, 2025, a federal court granted a preliminary injunction that blocks HUD from rolling back policies that were set to stay in place through 2026, and limits some unlawful funding restrictions on the Continuum of Care (CoC) Program.

The court’s order temporarily preserves lawful funding conditions and prevents the administration from shifting resources away from permanent housing and other proven, evidence-based solutions while the case proceeds. The injunction provides some immediate relief to local governments and service providers.

Read the ruling.

Update: 

In December, HUD issued a new funding notice after the plaintiffs challenged the November version. On January 14, 2026, the plaintiffs filed an amended complaint that challenges the December notice and adds an additional claim relating to HUD’s failure to award renewals from fiscal year 2024 funding. The December notice continues to impose harmful rules and conditions. And, it would continue to create large timing gaps in funding for programs that rely on stability. 

In the amended complaint and a motion for summary judgment filed the same day, we’re asking the court to declare both of HUD’s 2025 funding notices unlawful and order the agency to move forward with the CoC grants that were already approved in 2024. 

By changing the program conditions after required legal timelines, HUD is violating the Administrative Procedure Act. Additionally, HUD is violating the Constitution’s separation of powers by setting conditions that conflict with Congress’s intent when it approved this funding.

Read the amended complaint.