12/02/2025
**NLIHC President & CEO Renee M. Willis Statement - Litigation on HUD's 2025 CoC NOFO**
NLIHC partners, members, and friends,
This afternoon, the National Low Income Housing Coalition formally joined a federal lawsuit as a co-plaintiff, alongside Crossroads Rhode Island, Youth Pride, Inc., as well as the County of Santa Clara, California, San Francisco, California, King County, Washington, Boston, Massachusetts, Cambridge, Massachusetts, Nashville, Tennessee, and Tucson, Arizona, challenging harmful changes in the U.S. Department of Housing and Urban Development (HUD)’s Continuum of Care (CoC) Program Notice of Funding Opportunity (NOFO). We have also joined this suit alongside one of our closest national partners, the National Alliance to End Homelessness.
Democracy Forward serves as lead legal counsel for the case, and we are working closely with the National Homelessness Law Center for strategic legal partnership and alignment. Public Rights Project represents the cities of Boston, Cambridge, Nashville and Tucson. Santa Clara County and San Francisco represent themselves, and the ACLU Foundation of Rhode Island represents all plaintiffs.
Why NLIHC is taking action:
The Continuum of Care Program exists to house people experiencing homelessness using proven, evidence-based solutions and strong local leadership. Yet, this NOFO introduces structural restrictions that contradict its stated purpose — capping permanent housing resources, weakening local decision-making, and threatening the stability of community response systems nationwide.
As many as 170,000 more people could be pushed into homelessness if these changes stand — not as an abstract number, but as real individuals, families, veterans, seniors, youth, and neighbors in every state who depend on CoC-funded housing and services to remain stably housed.
What this lawsuit means for our field and partners:
We are fighting to:
• Prevent hundreds of thousands of people from losing their homes
• Protect proven permanent housing interventions within CoC funding
• Defend the ability of local communities to lead response strategies using data and evidence
• Stand with municipalities and providers working to keep people housed, stabilized, and supported
We are especially grateful to our partners in the field — including the North Carolina Coalition to End Homelessness and the Colorado Coalition for the Homeless — who have generously offered their expertise and perspective over the past several days. Their insights have helped us understand more clearly the community-level impact this NOFO would have on CoC partners and local housing systems. Their experience reinforces why this action matters, and we are sincerely grateful for their partnership.
Federal policy should be a source of housing stability — not a force that restricts it. We are stepping into this lawsuit because the people we serve cannot afford federal policies that weaken their communities’ ability to keep them housed.
NLIHC will continue to move forward responsibly, with care for our mission, our members, and the systems that protect households nationwide.
