New York Attorney General Letitia James today led a coalition of 20 other attorneys general in suing the federal administration to stop its unlawful attempt to gut lifesaving health, education, and social service programs for low-income families.  Earlier this month, in a chaotic reversal of decades of agency policy, the administration issued sweeping new directives barring many safety net programs from serving all residents, regardless of immigration status.  The changes threaten access to core services such as Head Start, Meals on Wheels, child welfare programs, domestic violence shelters, housing assistance, mental health treatment, food banks, and community health centers.  Attorney General James and the coalition are asking the court to halt these policies and act quickly to prevent the collapse of some of the nation’s most vital public programs.

“For decades, states like New York have built health, education, and family support systems that serve anyone in need,” said Attorney General James.  “These programs work because they are open, accessible, and grounded in compassion.  Now, the federal government is pulling that foundation out from under us overnight, jeopardizing cancer screenings, early childhood education, primary care, and so much more.  This is a baseless attack on some of our country’s most effective and inclusive public programs, and we will not let it stand.”

Starting on July 10, four federal agencies – the U.S. Departments of Health and Human Services (HHS), Education (ED), Labor (DOL), and Justice (DOJ) – issued a coordinated set of rules and guidance documents reinterpreting the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA), a 1996 law governing access to public benefits.  For nearly three decades, under both Democratic and Republican administrations, federal agencies interpreted PRWORA to allow states to offer a wide range of essential services without regard to immigration status.  That changed abruptly with new notices issued under the president’s executive order, “Ending Taxpayer Subsidization of Open Borders.”   The new policies redefine broad swaths of federally funded programs as restricted “federal public benefits,” now subject to immigration verification.  These rules took effect immediately or with little notice, bypassing public input and ignoring real-world consequences.  The policies apply not just to undocumented immigrants, but also to some people with legal status, including student visa holders, temporary workers, and exchange visitors.  In addition, the attorneys general warn that even U.S. citizens and lawful residents could be denied services, as many low-income individuals lack government-issued identification.

Attorney General James and the coalition argue the policies are already causing significant disruption.  The notices started to take effect almost immediately, and state programs face the risks of enforcement, endangering their federal funding.  Providers, including those serving children, pregnant patients, refugees, and other vulnerable populations, are ill-equipped to implement the new policies under any timeline.  Children in foster care, domestic violence survivors, people leaving homelessness, and many other vulnerable communities could lose access to some of their most critical supports.  Although some charitable organizations remain exempt from the requirement to verify immigration status, states and their subgrantees are not.  The attorneys general assert that in its rush to inflict harm on immigrant communities, the administration is poised to harm tens of thousands of low-income families, workers, and children, including U.S. citizens and lawful residents.  In New York, the consequences are especially alarming:

• Community Health Centers: New York’s 850 community health centers provide primary and preventative care to 2.4 million low-income residents, regardless of insurance or immigration status.  These centers are often the only healthcare provider available in underserved communities.  Without federal funding or reimbursement for treating patients whose status cannot be verified, many centers could be forced to close – leaving entire communities without access to vaccines, mammograms, wellness exams, and chronic disease care.
• Title X Family Planning Clinics: Title X clinics provide low- or no-cost reproductive care, STI testing, cancer screenings, and wellness exams to over 300,000 New Yorkers each year.  In 2024, the state received more than $11 million in Title X funding – all of which may now be at risk unless clinics begin screening for verifying immigration status, a step providers call unworkable and deeply harmful.
• Anti-Poverty Programs: New York receives approximately $65 million annually through the Community Services Block Grant, which supports food, housing, utility assistance, and more.  In 2023, the state’s Community Action Agencies served more than half a million New Yorkers, distributed 1.5 million boxes of food, and provided before- and after-school programs for over 200,000 students.  Under the new rules, far fewer people will access these critical anti-poverty services – either because they lack ID or because they fear immigration-related repercussions.
• Early Childhood Education: Head Start provides early education to 43,000 low-income children at nearly 1,000 sites statewide and receives approximately $700 million in federal funding.  New York’s Head Start providers warn that they may not have the ability or capacity to feasibly implement immigration screening.  These programs are particularly fragile: when federal funding was temporarily frozen in January 2025, several centers shut down within days, forcing parents to miss work and threatening job stability.
• Behavioral Health: New York receives nearly $180 million annually in federal mental health and substance use block grant funding to support critical programs like crisis intervention teams, substance use disorder treatment, school-based mental health services, peer support networks, the 988 suicide and crisis lifeline, and jail diversion initiatives.  These services are now at serious risk under the new federal rules.  For many individuals with serious mental illness - including those experiencing homelessness - immigration status screening and documentation requirements may pose an insurmountable barrier to care.  The New York Office of Mental Health also warns that these changes could severely undermine the state's mental health infrastructure and further worsen the nationwide youth mental health crisis.
• Adult Education Services: More than 80,000 New Yorkers use Adult Career and Continuing Education Services (ACCES) each year to build literacy, earn high school equivalency diplomas, and gain career training.  These programs are especially vital for new Americans and are essential to addressing workforce shortages.  The administration’s rules would exclude thousands of learners overnight and destabilize the entire system.  Providers warn they cannot implement the new requirements without gutting their mission and ability to serve.

The attorneys general argue that the federal government acted unlawfully by issuing sweeping new mandates without following the required rulemaking process, in violation of the Administrative Procedure Act.  They also argue the administration grossly misread PRWORA, improperly applying it to entire programs rather than individual benefits, and generally failed to consider the sweeping and devastating impacts these changes would have on states.  Finally, they assert the rules violate the Constitution’s Spending Clause, which requires the federal government to provide clear and fair notice of any new conditions on funding before states accept those funds.  Attorney General James and the coalition are asking the court to declare the new rules unlawful, halt their implementation through preliminary and permanent injunctions, vacate the rules and restore long-standing practice, and prevent the federal government from using PRWORA as a pretext to dismantle core safety net programs in the future.

Joining Attorney General James in filing this lawsuit are the attorneys general of Arizona, California, Colorado, Connecticut, Hawaii, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New Mexico, Oregon, Rhode Island, Vermont, Washington, Wisconsin, and the District of Columbia.