State of New York et al. v. U.S. Department of Justice et al.

Issue: Whether federal agencies’ changes to the longstanding interpretations of the “public benefits” subject to PRWORA’s restrictions on immigrants’ access violate the APA and the Spending Clause of the U.S. Constitution?

Background: This case challenges the Trump Administration’s efforts to restrict immigrant access to federal programs by reinterpreting the longstanding definitions of programs considered “public benefits” under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA). In July 2025, the Department of Health and Human Services (HHS) issued a notice expanding the scope of federal benefits subject to PRWORA's requirement to exclude immigrants to include the Health Center Program, Head Start, Title X, and behavioral health services, among others. Other federal agencies, including the Department of Justice (DOJ), Department of Labor (DOL), Department of Education (ED), and the Department of Housing and Urban Development (HUD), issued similar notices expanding the programs considered “public benefits” under PRWORA.

20 states and the District of Columbia are suing DOJ, HHS, DOL, ED, and HUD over these changes, alleging that new policies violate the Administrative Procedures Act (APA) because they are arbitrary and capricious and contrary to law. The plaintiffs also allege Spending Clause violations, claiming the agencies unconstitutionally changed federal funding conditions and imposed retroactive conditions. Plaintiffs seek the court to declare the notices unlawful and enjoin the agencies from enforcing them.

On September 21, 2026, the District Court granted summary judgment for the plaintiff states, vacating the new guidances from DOJ, HHS, HUD, DOL, and ED. This means that, for now, the new guidance cannot be enforced against anyone.

Current status: Summary judgment was granted for the plaintiff states, and the guidance from DOJ, HHS, HUD, DOL, and ED was vacated.

Public Health Deans and Scholars Amicus Brief

Amici: American Public Health Association, Robert Wood Johnson Foundation, National Center for Medical-Legal Partnership, Jacobs Institute of Women’s Health, and 65 public health deans and scholars.

Argument Summary: HHS’ actions are arbitrary and capricious because it failed to consider important aspects of the problem. These changes barring certain immigrants from participating in health programs newly categorized as “public benefits” under PRWORA will have devastating consequences for individual health, public health, and the economy. Millions of immigrant adults, children, and pregnant people will no longer be able to get the healthcare they need. These changes will also result in a chilling effect, causing eligible immigrants to forgo accessing care to which they are entitled. In addition, these changes are contrary to law because they are inconsistent with the programs’ authorizing statutes that require them to serve the entire community.

Outside Counsel: Manatt, Phelps & Phillips, LLP and the Lawyers’ Committee for Rhode Island

Related Resources:

Public Comment Letter. U.S. Department of Health and Human Services. August 15, 2025.

GW Media Relations. Leading Public Health Experts Urge Federal Court to Block HHS Policy Restricting Immigrants’ Access to Essential Health Programs. March 9, 2026. https://publichealth.gwu.edu/leading-public-health-experts-urge-federal-court-block-hhs-policy-restricting-immigrants-access

Citations:

"A group of public health organizations and scholars on Friday urged a Rhode Island federal court to make permanent its order blocking the Trump administration from enacting a policy change basing access to a host of federally funded services on immigration status."

Ferrarin G. Health Groups Back Bid To Bar Noncitizen Benefit Restrictions. Law 360. Mar. 6, 2026. https://www.law360.com/articles/2449932/health-groups-back-bid-to-bar-noncitizen-benefit-restrictions

Funding Acknowledgement: Support for this program is provided by the Commonwealth Fund and the Robert Wood Johnson Foundation. The views presented here are those of the authors and not necessarily those of the Commonwealth Fund, its directors, officers, or staff, or the Robert Wood Johnson Foundation.