On April 15, 2025, the federal district court for the District of Rhode Island granted six nonprofit organizations’ request for a preliminary injunction enjoining five federal agencies from freezing “on a non-individualized basis” the processing and payment of funding appropriated under the Inflation Reduction Act (IRA) or the Infrastructure Investment and Jobs Act (IIJA) that had already been awarded. The agencies were the U.S. Department of Energy, the U.S. Environmental Protection Agency (EPA), the U.S. Department of Housing and Urban Development (HUD), the U.S. Department of the Interior, and U.S. Department of Agriculture. Funding at issue in the case included a grant to support localities with plans to plant more trees and manage existing forests under the IRA’s Urban and Community Forestry Program and a grant through HUD’s Green and Resilient Retrofit Program funded by the IRA. The court also ordered the Office of Management and Budget (OMB) and the National Economic Council (NEC) Director to notify agencies not to implement their memorandum directing agencies to pause disbursement of funds supporting “Green New Deal” programs implicated by the policy set forth in President Trump’s “Unleashing American Energy” executive order. The court found that the organizations demonstrated standing against all defendants and that the doctrine of claim-splitting did not narrow their case despite some plaintiffs being involved in litigation challenging federal funding freezes in another court. The court also said it was “confident” that it had jurisdiction under the Administrative Procedure Act (APA) because the agency actions were final and the organizations’ claims were not “simple contract actions for money damages” that would be required to be heard in the Court of Federal Claims. On the merits, the court found that the organizations demonstrated a strong likelihood of success on their APA claim that the freeze of awarded funds was arbitrary and capricious because the freeze was not reasonable or reasonably explained and failed to account for reliance interests. The court also found that federal law did not authorize the “broad powers” asserted by the five agencies and by OMB and the NEC Director, even if the agencies “likely possess narrower powers related to individualized funding pauses and terminations.” The court also found that the organizations adequately demonstrated irreparable harm and that the balance of the equities and the public interest “weigh heavily” in favor of injunctive relief. The court—which declined to require the organizations to provide a bond—concluded that a nationwide injunction was appropriate. The federal government appealed the injunction to the First Circuit.

Nonprofit organizations' lawsuit challenging the Trump administration's freezing of funding under the Inflation Reduction Act and the Infrastructure Investment and Jobs Act.

Woonasquatucket River Watershed Council v. U.S. Department of Agriculture

<p>This entry was provided by the Sabin Center for Climate Change Law. Please see the terms of use for citation and licensing of third party data.</p>

Court Barred Federal Agencies from Freezing Inflation Reduction Act and Infrastructure Investment and Jobs Act Funding

Filed

The Climate Litigation Database

Find climate change litigation data and indicators for {text}.

{text} litigation

Sabin Center for Climate Change Law provides Climate Litigation Database, a comprehensive database of US and Global climate change caselaw

Quickly and easily search through the complete text of thousands of climate change law and policy documents from every country.

Search the Climate Litigation Database

An aim to achieve a quantifiable outcome within a given time-frame, set by an institution such as a national government.

Policy instruments are techniques or tools used by governing authorities to promote certain policies in order to achieve predetermined goals. Put simply, instruments are how a government tries to achieve its goals, with this taxonomy being focused on national policy instruments.

Risk is the potential for adverse consequences resulting from the dynamic interplay between (climate-related) hazards, exposure, and vulnerability of affected human or ecological systems.

Groups  of people who are adversely affected by climate change or the response to it

A set of principles, processes, and practices that build economic and political power to shift from an extractive economy to a regenerative economy.

Justice is the ethical and political framework that addresses fairness, including issues of responsibility, rights, and structural inequity.

Renewable energy means all forms of energy produced from renewable sources in a sustainable manner.

Fossil fuel is a generic term for non-renewable energy sources such as coal, fossil gas, and oil (including crude oil, and petroleum products), that can be used for electricity and heat generation. Fossil fuels are hydrocarbons formed from pressurised and heated organic material buried over millions of years.

Molecules in the atmosphere that play a key role in the greenhouse effect by trapping heat radiating from Earth’s surface.

Area of the economy in which actors engage in identical or related activities.

In human systems, the process of adjustment to actual or expected climate change and its effects, in order to moderate harm, increase resilience or exploit beneficial opportunities. In natural systems, the process of adjustment to actual climate change and its effects; human intervention may facilitate adjustment to expected climate change and its effects.

The management and allocation of funds, assets and investments to meet various objectives

A loan is a policy instrument where funds are provided to a borrower with the expectation of repaying the principal plus interest.

Direct investments by the governments using public funds. This can be to support climate initiatives or integrate climate into other projects.

A ban is a legal action that prevents the sale or supply of a product or service, or that recalls a product from the market. Examples are bans on SF6, greenwashing, fossil fuel advertisement or single-use plastics.

Either money or something of monetary value is transferred between two or more organisations, people or countries.

Replacing technologies that burn fossil fuels directly with alternatives powered by electricity.

Actions to reduce emissions in energy generation and supply.

Extreme weather refers to events where a weather variable exceeds (or falls below) a threshold. Meaning it is significantly different from the average or usual weather pattern.

Terrestrial means "of the earth" and relates to the risks to ecological system that includes all living organisms and their interactions within land-based environments, such as forests, grasslands, and deserts.

Social protection systems consist of policies that help people manage social risks in order to prevent poverty and maintain decent incomes and living standards

Oil is a combustible liquid fossil fuel composed mainly of hydrocarbons, occurring as crude oil and refined into petroleum products such as petrol, diesel and kerosene.

Fossil gas, commonly known as natural gas, is a fossil fuel consisting chiefly of methane with smaller amounts of other hydrocarbons and trace gases, found in underground deposits.

Coal is a combustible sedimentary rock formed from carbonised plant matter, rich in carbon and hydrocarbons, and occurring in several main types including hard coal and brown coal.

People with different national or cultural traditions from the dominant population

Social and cultural groups that share collective ancestral ties to the lands and natural resources where they live, occupy or from which they have been displaced

Work that is productive and delivers a fair income, security in the workplace and social protection for all, better prospects for personal development and social integration, freedom for people to express their concerns, organize and participate in the decisions that affect their lives and equality of opportunity.

woman and genders outside of the gender binary

The activities of industries that transforms raw materials into finished goods through industrial processes.

Activities that involve planning, designing and building infrastructure, residential, and commercial structures.

This sector involves the wholesale and retail selling of goods.

This sector involves activities that impart knowledge and skills to individuals, including formal schooling, vocational training and educational support.

This sector includes firms and individuals offering specialised expertise in fields such as law, accounting, consulting, science and engineering.

Activities that involve the cultivation of crops and raising of livestock for food, fibre, and other products essential for human life and industry.

Geohazards are adverse geological phenomenon's that are capable of causing widespread damage or loss to property, life and the environment, such as earthquakes, volcano eruptions and tsunamis. Climate change can increase the frequency and severity of some geohazards, such as landslides, and soil erosion.

Court Barred Federal Agencies from Freezing Inflation Reduction Act and Infrastructure Investment and Jobs Act Funding

Policy instrument

Risk

Impacted group

Just transition

Renewable energy

Fossil fuel

Greenhouse gas

Economic sector

Finance