Filed Date: March 17, 2025
Closed Date: April 14, 2025
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This case challenged Trump’s Executive Orders 14151 and 14173, which cut government funding for “equity-related” programs. On March 17, 2025, Erie County, New York, filed a lawsuit in the United States District Court for the District of Columbia against the Corporation for National and Community Service (commonly known as AmeriCorps) and its interim agency head. The case was assigned to Judge James Emanuel Boasberg. Erie County sought declaratory and injunctive relief, claiming that AmeriCorps’ actions violated the Administrative Procedure Act and the Spending Clause of the U.S. Constitution.
The dispute arose after Erie County applied for and was awarded a three-year Retired and Senior Volunteer Program (RSVP) grant from AmeriCorps in October 2023. The grant, which supports volunteer services such as the Meals on Wheels program, was approved in January 2024. However, after the issuance of Executive Order 14151 on January 20, 2025—titled “Ending Radical Government DEI Programs and Preferencing”—AmeriCorps began reviewing grant recipients for compliance with the order’s mandate to eliminate “equity-related” programs. The following day, President Trump issued Executive Order 14173, requiring federal grant recipients to certify that they did not operate programs promoting Diversity, Equity, and Inclusion (DEI) that violated federal antidiscrimination laws. AmeriCorps subsequently demanded that Erie County either amend its grant application, certify its compliance with all administration executive orders, or relinquish the award.
In February 2025, Erie County received multiple communications from AmeriCorps stating that noncompliance with the executive orders could result in grant termination. In response, the county pointed to a temporary injunction against Executive Order 14151 issued by the U.S. District Court for the District of Maryland. See National Association of Diversity Officers in Higher Education v. Trump. AmeriCorps initially paused enforcement but continued to impose additional conditions on grant applications.
In its complaint, Erie County claimed that AmeriCorps’ enforcement of the executive orders was arbitrary, capricious, and exceeded its lawful authority under the Administrative Procedure Act. The county also alleged that the vague and undefined requirements of the orders violated the Spending Clause by coercing local governments into compliance with federal conditions that lacked a clear legal basis. Erie County argued that AmeriCorps’ demands were unlawful, as its regulations had long required applicants to promote community diversity in their programs. The county refused to certify that its RSVP program did not promote DEI, noting that it had operated in full compliance with AmeriCorps regulations. The lawsuit sought a court order enjoining AmeriCorps from imposing additional grant requirements beyond those established by law and from enforcing Executive Orders 14151 and 14173 against the county.
On March 21, 2025, the plaintiffs filed a motion for a preliminary injunction. They asked the Court to require the "Defendants to determine Plaintiff is in compliance with all relevant grant requirements for existing RSVP grants, and to disburse immediately any funds to which it is entitled, without Plaintiff needing to certify that “RSVP of Erie County, 24SR260017 complies with all administration Executive Orders and does not include any activities that promote DEI activities,” or make any other substantially similar certification referencing compliance with executive orders and promotion of DEI activities." The defendants filed their motion in opposition to the preliminary injunction on April 4, 2025, arguing the "Plaintiff ha[d] not demonstrated that it is at imminent risk of irreparable harm, that it is likely to succeed on the merits, or that the balance of the equities is in its favor."
Summary Authors
Jillian Snyman (3/19/2025)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69747050/parties/erie-county-new-york-v-corporation-for-national-and-community-service/
Gerstein, Charles Lewis (District of Columbia)
Harrow, Jason Seth (District of Columbia)
Jones, Sian (District of Columbia)
See docket on RECAP: https://www.courtlistener.com/docket/69747050/erie-county-new-york-v-corporation-for-national-and-community-service/
Last updated April 21, 2025, 3 p.m.
State / Territory: District of Columbia
Case Type(s):
Presidential/Gubernatorial Authority
Special Collection(s):
Trump Administration 2.0: Challenges to the Government
Trump Administration 2.0: Challenges to the Government (Spending Freezes/Cuts)
Key Dates
Filing Date: March 17, 2025
Closing Date: April 14, 2025
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Plaintiff Erie County, New York, is a municipal entity formed by the laws of New York. Its county seat is Buffalo.
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
The Corporation for National and Community Service, Federal
Defendant Type(s):
Case Details
Causes of Action:
Ex Parte Young (Federal) or Bivens
Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.
Declaratory Judgment Act, 28 U.S.C. § 2201
Ex parte Young (federal or state officials)
Constitutional Clause(s):
Spending/Appropriations Clauses
Available Documents:
Outcome
Prevailing Party: None Yet / None
Source of Relief:
Issues
Presidential/Gubernatorial Authority: