In a lawsuit filed today in U.S. District Court in Rhode Island, a broad coalition of local governments and nonprofit organizations across the country — including Rhode Island-based nonprofits Crossroads Rhode Island and Youth Pride, Inc. — is seeking to stop the Trump-Vance administration from creating unlawful and unreasonable restrictions for funding for proven solutions to homelessness, threatening to push hundreds of thousands of people onto the street as cold winter months arrive.
For years and through multiple administrations, the U.S. Department of Housing and Urban Development (HUD)’s Continuum of Care (CoC) Program has helped provide the necessary resources for local governments and organizations to fund permanent housing projects for veterans, the elderly, people with disabilities, and individuals and families experiencing homelessness. On November 13, 2025, however, without explanation, HUD rescinded elements of this program, replacing it with one that threatens existing services. This move, which could push hundreds of thousands of Americans into homelessness, is being done on a compressed timeline and throwing the entire program, meant to ensure stability for programs and the people who rely on them, into chaos.
After more than a decade of prioritizing evidence-based approaches that reduce homelessness, as the complaint explains, the new Notice of Funding Opportunity (NOFO) for FY 2025 upends the stability of the program required by law, will have devastating impacts for plaintiffs, and cause hundreds of thousands of children, youth, adults, and families to become homeless. The NOFO makes drastic changes at every step of the process — by changing the types of projects eligible for funding, the criteria for selecting awardees, and the conditions grantees will be required to accept in order to receive funding. The Rhode Island local CoC application deadline is December 12, 2025.
For Crossroads Rhode Island, the largest homeless service provider in the state, the new NOFO presents “an impossible choice.” The complaint explains that the organization will have to:
"either (1) attempt to comply with the new requirements and preferences and betray its mission, abandon the clients it serves, jeopardize compliance with professional ethical standards, and face enormous risks of litigation and government inquiry under the False Claims Act and state and federal civil rights laws, or (2) forgo applying for or accepting HUD CoC awards and face devastating consequences by cutting off supportive services and rental assistance to hundreds of households across the state."
Similarly, Youth Pride, Inc. provides housing assistance to LGBTQ+ youth ages 18-24. As detailed in the complaint, if the organization does not apply for CoC funds, “the critical housing assistance that Youth Pride provides would end, leaving some of Rhode Island’s most vulnerable youth homeless without support.
Among other claims, today’s suit raises a First Amendment challenge to a new funding condition that threatens to reject any applicant that has used or uses “a definition of sex other than as binary in humans.” The suit also argues that HUD’s new policies are contrary to federal law, and arbitrary and capricious in violation of the Administrative Procedure Act,
Besides Crossroads Rhode Island and Youth Pride, Inc., the coalition behind the new legal challenge includes the National Alliance to End Homelessness (NAEH) and the National Low Income Housing Coalition (NLIHC), as well as the County of Santa Clara, Calif., San Francisco, Calif., King County, Wash., Boston, Mass., Cambridge, Mass., Nashville, Tenn., and Tucson, Ariz. Democracy Forward represents 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; and Santa Clara County and San Francisco represent themselves. The Lawyers’ Committee for Rhode Island and the ACLU Foundation of RI represent all plaintiffs.