Original Date Announced

OMB Acting Director Matthew J. Vaeth issued a memo addressed to all heads of executive departments and agencies on "Temporary Pause of Agency Grant, Loan, and Other Financial Assistance Programs." The memo directed Federal agencies to "temporarily pause all activities related to obligation or disbursement of all Federal financial assistance, and other relevant agency activities that may be implicated by" Trump administration executive orders, including "financial assistance for foreign aid, nongovernmental organizations, DEI, woke gender ideology, and the green new deal." During the pause, agencies must review all federal assistance programs for consistency with Trump's executive orders and submit "detailed information" to OMB on "any programs, projects or activities subject to this pause" by February 10, 2025.

The funding freeze would affect programs that assist noncitizens in the U.S., including EOIR's Office of Legal Access Programs, that were addressed by EO 14159, Protecting the American People Against Invasion.

Trump 2.0 [ID #1505]

Subsequent Trump and Court Action

2025.01.28 AP News: Federal judge temporarily blocks Trump administration freeze on federal grants and loans

In Nat'l Council of Nonprofits v. OMB, No. 25-cv-00239 (D.D.C.), Judge Loren L. AliKhan issued an “administrative stay” enjoining the Trump administration from implementing OMB Memorandum M-25-13. This administrative stay is scheduled to last until February 3, 2025.

*See litigation note above*

Subsequent Trump and Court Action

2025.01.28 OMB Q&A Regarding Memorandum M-25-13

OMB provided a Q&A Factsheet intended to clarify how agencies implement the M-25-13 directive: “the pause does not apply across-the-board. It is expressly limited to programs, projects, and activities implicated by the President’s Executive Orders, such as ending DEI, the green new deal, and funding nongovernmental organizations that undermine the national interest.”

Subsequent Trump and Court Action

2025.01.28 Nat'l Council of Nonprofits v. OMB, No. 25-239 (D.D.C.) - Complaint

Advocacy groups representing non-profits and small businesses filed a federal lawsuit challenging the "Temporary Pause of Agency Grant, Loan, and Other Financial Assistance Programs." Nat'l Council of Nonprofits v. OMB, No. 1:25-cv-00239 (D.D.C.).

**Litigation entries are limited to initial complaints and major substantive rulings. For pleadings and additional information, use name and docket number to search Civil Rights Clearinghouse and CourtListener or visit Just Security Litigation Tracker**

Subsequent Trump and Court Action

2025.01.28 New York et al. v. Trump, No. 1:25-cv-00039 (D.R.I.) - Complaint

23 states filed a federal lawsuit in Rhode Island challenging the "Temporary Pause of Agency Grant, Loan, and Other Financial Assistance Programs." New York v. Trump, No. 1:25-cv-00039 (D.R.I.).

*See litigation note above*

Subsequent Trump and Court Action

2025.01.29 OMB Memo M-25-14 Rescinding Funding Freeze

OMB issued Memo M-25-14 rescinding M-25-13. This memo informed federal agencies that the January 27, 2025, funding freeze on federal financial assistance programs, outlined in M-25-13, had been rescinded.

Subsequent Trump and Court Action

2-025.01.31 New York et al. v. Trump, No. 1:25-cv-00039 (D.R.I.) - Order Granting TRO

In New York v. Trump, No. 1:25-cv-00039 (D.R.I.), Judge John J. McConnell issued a Temporary Restraining Order (TRO) blocking the Trump administration's efforts to freeze payments for grants and other programs.

*See litigation note above*

Subsequent Trump and Court Action

2025.02.03 Nat'l Council of Nonprofits v. OMB, No. 25-239 (D.D.C.) - Order Granting TRO

In Nat'l Council of Nonprofits v. OMB No. 25-cv-00239 (D.D.C.), Judge AliKhan issued an Temporary Restraining Order (TRO) blocking the Trump administration from implementing OMB Memorandum M-25-13.

*See litigation note above*

Subsequent Trump and Court Action

2025.2.25 Nat'l Council of Nonprofits v. OMB, 1:25-cv-00239-LLA (D.D.C.) - Preliminary Injunction Opinion

In Nat'l Council of Nonprofits v. OMB, No. 25-cv-00239 (D.D.C.), Judge AliKhan preliminarily enjoined the Trump administration from implementing, giving effect to, or reinstating under a different name the freeze on disbursement of federal funds.

**Litigation entries are limited to initial complaints and major substantive rulings. For pleadings and additional information, use name and docket number to search Civil Rights Clearinghouse and CourtListener or visit Just Security Litigation Tracker**

Subsequent Trump and Court Action

2025.03.03 Complaint - Catholic Charities, Diocese of Forth Worth v. U.S. Dept. of Health and Human Services

Catholic Charities, Diocese of Fort Worth ("CCFW") sued HHS in the D.C. District Court for unlawfully freezing federal funding and then failing to un-freeze federal grant funds obligated to CCFW for its refugee resettlement work, despite the government's rescission of OMB Memo M-25-13. CCFW seeks declaratory and injunctive relief. Catholic Charities, Diocese of Forth Worth v. U.S. Depot of Health and Human Services, 1:25-cv-00605 (D.D.C., filed on Mar. 3, 2025).

*See litigation note above*

Subsequent Trump and Court Action

2025.03.06 Order Granting Preliminary Injunction - New York v. Trump

In New York et al. v. Trump, No. 1:25-cv-00039 (D.R.I.), Judge John J. McConnell issued a preliminary injunction blocking the Trump administration's efforts to freeze payments for grants and other programs. The court held “that the Executive’s discretion to impose its own policy preferences on appropriated funds can be exercised only if it is authorized by the congressionally approved appropriations statutes.”

*See litigation note above*

Subsequent Trump and Court Action

2025.04.08 Complaint - Harris County, Texas v. DHHS

Harris County sued the Trump administration to challenge the withholding of federal funding for the county’s Refugee Health Services Program, which provides health screenings, vaccinations, and connections to primary care services to refugees and other immigrants. The lawsuit argues the funding freeze violates the separation of powers under the Constitution as well as the Administrative Procedure Act, and asks a judge to compel the federal government to disperse funding authorized by Congress. Harris Cnty., Texas v. U.S. Dep't of Health & Hum. Servs., No. 1:25-cv-01058 (D.D.C.).

**See litigation notes above**

Subsequent Trump and Court Action

2025.04.17 Harris County Lawsuit Forces Trump Administration to Restore Refugee Health Funds

The Trump administration restored funding for Harris County’s Refugee Medical Screening Program. The administration claimed funds were frozen due to an audit of the County’s program. After the federal district court in Harris Cnty., Texas v. U.S. Dep't of Health & Hum. Servs. ordered the administration to provide clear timelines for disbursing the funds, funding of the program resumed.