Rhode Island AFL-CIO v. EPA

On September 18, 2026, the federal district court for the District of Rhode Island vacated EPA’s August 2025 termination of Solar for All (SFA), a $7 billion grant program established under the Inflation Reduction Act’s Greenhouse Gas Reduction Fund. The plaintiffs were “downstream beneficiaries” of SFA, including solar energy companies, an individual who applied to receive roofing and solar paneling services under an SFA program, a labor union that helped to develop an implementation plan for an SFA program, and nonprofits that were SFA subgrantees or otherwise benefited from SFA. The court found that at least one of these plaintiffs (a solar energy company) had standing to challenge the “programmatic decision” to terminate SFA. The court also rejected other jurisdictional defenses, including the defendants’ argument that the plaintiffs’ claims were challenges to grant terminations that could only be brought in the Court of Federal Claims pursuant to the Tucker Act. The court also rejected arguments that the plaintiffs challenged a decision that was not a final agency action and that was committed to agency discretion. On the merits, the court found that the defendants acted contrary to the intent of the One Big Beautiful Bill Act, which repealed the Greenhouse Gas Reduction Fund statutory provision and rescinded only “unobligated balances of amounts made available to carry out that section.” The court concluded that “Congress’s clear intent was that EPA continue to administer the already obligated SFA grants” and that the termination decision therefore was contrary to law and in excess of the defendants’ statutory authority in violation of the Administrative Procedure Act. The court did not reach the plaintiffs’ constitutional claims. The court further concluded that vacatur of the termination decision was the appropriate remedy and that a permanent injunction was not warranted.

A labor organization, an individual homeowner, and nonprofit organizations who identified themselves as the “intended beneficiaries” of the Solar for All program filed a lawsuit in the District of Rhode Island challenging the U.S. Environmental Protection Agency's termination of the program. They alleged that they would have benefitted directly from the program’s provision of new energy sources and its electricity cost savings. They asserted that the program’s termination violated the Administrative Procedure Act and was ultra vires, in violation of separation of powers and the Presentment Clauses.