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 Complaint - National Council of Nonprofits v. OMB

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.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.01.28 Complaint - New York v. Trump

23 states filed a federal lawsuit challenging the OMB memo described above. New York v. Trump, No. 1:25-cv-00039 (D.R.I.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.01.28 Order - National Council of Nonprofits v. OMB

District 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. Nat'l Council of Nonprofits v. OMB, No. 1:25-cv-00239 (D.D.C.).

**Link to case here. Our litigation entries generally report only the initial complaint and any major substantive filings or decisions. For additional information, CourtListener provides access to PACER and all available pleadings. Other sites that track litigation in more detail or organize cases by topic include Civil Rights Clearinghouse, Justice Action Center, National Immigration Litigation Alliance, and Just Security**

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 DHS - Direction on Grants to Non-governmental Organizations

DHS Secretary Kristi Noem issued a memorandum placing "on hold pending review, except to the extent required by controlling legal authority," all DHS grant disbursements and assessments of grant applications that: (1) go to non-profit organizations or for which non-profit organizations are eligible; and (b) "touch in any way on immigration." As justification, the memorandum cites "concerns that these grants may be funding illegal activities," "concerns that there may be racially discriminatory language in certain grants," and "concerns that these grants may not be an efficient use of government resources."

The memorandum was made public through litigation in Solutions in Hometown Connections v. Noem, No. 8:25-cv-00885 (D. Md.).

For additional information and updates on this change, please see this Trump 2.0 entry.

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

2025.01.31 Order Granting Temporary Restraining Order - New York v. Trump

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

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.02.03 Order Granting Temporary Restraining Order - National Council of Nonprofits v. OMB

District Judge AliKhan issued a temporary restraining order blocking the Trump administration from implementing OMB Memorandum M-25-13. In Nat'l Council of Nonprofits v. OMB No. 25-cv-00239 (D.D.C.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.02.25 Order Granting Preliminary Injunction - National Council of Nonprofits v. Trump

District 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. Nat'l Council of Nonprofits v. OMB, No. 1:25-cv-00239 (D.D.C.).

**Link to case here. See litigation note above**

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 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 Fort Worth v. U.S. Dep't of Health and Human Services, No. 1:25-cv-00605 (D.D.C.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.03.06 Order Granting Preliminary Injunction - New York v. Trump

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

**Link to case here. 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.).

**Link to case here. See litigation notes above**

Subsequent Trump and Court Action

2025.04.17 Harris County Attorney's Office - Lawsuit Forces Trump Administration to Restore Refugee Funds

The Harris County Attorney's Office announced that 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.

Subsequent Trump and Court Action

2026.03.16 Opinion - New York v. Trump

The First Circuit affirmed in part the district court's March 6, 2025 preliminary injunction and vacated it in part. Among other things, it upheld the district court's finding that the plaintiffs were likely to succeed on the merits of their APA claim. However, the court held that the injunction was overbroad in certain respects and vacated it insofar as it required the government defendants to disburse funds to the states under awarded grants and executed contracts, finding that such relief is barred by the Tucker Act. New York v. Trump, No. 25-1236 (1st Cir.).

**Link to case here. See litigation note above**