William Tong fights HUD rules that could cut Connecticut housing aid

HUD Secretary Scott Turner announced a major overhaul of the Continuum of CareContinuum of CareHUD funding networks for homelessness services.Key ConceptContinuum of CareHUD funding networks for homelessness services.Open conceptBookmark grant program in late 2025, cutting the share of federal funds available for permanent supportive housing from approximately 90 percent to a maximum of 30 percent. The CoC program distributes roughly $3.9 billion annually to local homelessness networks. Turner framed the shift as ending a program that "perpetuated homelessness" by not requiring treatment or employment before placing people in housing.

Connecticut AG William Tong joined attorneys general from 19 other states and the District of Columbia in suing HUD in November 2025 to block the new CoC funding conditions. The coalition argued HUD had no authority to impose the new conditions without formal rulemaking under the Administrative Procedure ActAdministrative Procedure Act1946 law governing how federal agencies develop regulations and make decisions through rulemaking and adjudication.Key ConceptAdministrative Procedure Act1946 law governing how federal agencies develop regulations and make decisions through rulemaking and adjudication.Open conceptBookmark.

U.S. District Judge Mary McElroy in Rhode Island ruled on March 31, 2026 that HUD violated the APA by making "major, disruptive" changes to multi-year grants without proper notice-and-comment rulemaking. Her ruling upheld a preliminary injunction blocking the new CoC conditions from taking effect.

The U.S. Court of Appeals for the First Circuit affirmed McElroy's ruling on April 1, 2026, finding that implementing the HUD conditions would be "immediately destabilizing and disastrous" for the roughly 170,000 people in federally subsidized permanent supportive housing who would have faced displacement.

HUD's proposed conditions would have required CoC-funded programs to ask about immigration status before providing services, recognize only two genders in program eligibility determinations, mandate sobriety or psychiatric commitment as a pathway to housing, and redirect funding from permanent housing to transitional shelters. all conditions cited in court as conflicting with existing statutory and regulatory frameworks.

Housing FirstHousing FirstA homelessness policy that starts with stable housing.Key ConceptHousing FirstA homelessness policy that starts with stable housing.Open conceptBookmark is an evidence-based approach that places people directly into permanent housing without requiring sobriety, employment, or treatment compliance as preconditions. The model has been federal policy from the Obama through Biden administrations and is supported by over 200 peer-reviewed studies documenting reduced emergency shelter use, hospitalization, and incarceration costs compared to treatment-first approaches.

Connecticut operates a Housing First system through seven regional Coordinated Access Networks that rank vulnerable individuals using a standardized vulnerability index and prioritize them for permanent housing placement. An estimated 4,000 Connecticut residents were in permanent supportive housing funded under the CoC program when HUD announced the overhaul.

CT Insider reported on June 12, 2026 that Connecticut officials remained alarmed by the administration's ongoing efforts to shift homelessness policy away from Housing First. Gov. Ned Lamont and Mental Health Commissioner Nancy Navarretta opposed the changes, warning that even a revised HUD rule could disrupt the state's coordinated homelessness response infrastructure.

Roll Call reported in May 2026 that HUD was preparing a revised version of its CoC competition rules after courts blocked the first attempt. Turner testified before Congress on May 12 and May 14, 2026, defending the administration's homelessness approach and signaling the policy effort would continue through formal rulemaking.

The APA requires federal agencies to publish proposed rules in the Federal Register, accept written public comments over a minimum 30-day period, respond to significant comments in the final rule, and justify the decision with evidence before it takes effect. HUD skipped this process when it imposed new CoC conditions through a funding notice. the procedural shortcut courts found fatal to the agency's position.

The Continuum of Care statute (42 U.S.C. § 11381 et seq.) authorizes HUD to set grant eligibility criteria, but courts have held that major changes to existing multi-year grant conditions trigger APA requirements even when the underlying authorization gives an agency broad discretion. The March 31 ruling is part of a larger pattern of courts applying APA procedural requirements to grant condition changes the Trump administration made without notice-and-comment.