On March 11, 2025, CCR, Amica Center and Florence Project submitted a FOIA request to the Department of Health and Human Services (HHS) seeking records concerning the February 18, 2025 “stop work” order that HHS, through the Department of the Interior, issued to contractors and subcontractors providing legal services to unaccompanied children who were or had been in ORR custody, including Amica and Florence Project. This “stop work” order was inexplicably rescinded a few days later on February 21, 2025.

Upon information and belief, HHS was planning to stop funding legal services for unaccompanied non-citizen children and replace those services with “Know Your Rights” videos once the current contract expired on March 29, 2025. On March 21, 2025, HHS, again through the Department of the Interior, terminated the majority of the services provided under the contract between HHS and Acacia Center for Justice. These services, provided by a consortium of nonprofit legal organizations including Plaintiffs, were critical to ensuring compliance with statutory mandates under the Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA), which requires the government to ensure “to the greatest extent practicable” that unaccompanied children are provided access to legal counsel.

In response to the termination, a coalition of legal service providers filed suit, alleging that the administration’s actions violated both federal procurement law and statutory protections under the TVPRA. See Community Legal Services of East Palo Alto, et al., v. Department of Health and Human Services, No. 3:25-cv-02847 (N.D. Cal. Mar. 26, 2025). The district court judge in that matter issued a temporary restraining order and then a preliminary injunction enjoining the termination and ordering the government to restore funding and reinstate services pending further proceedings. 

Following these rulings, defendants restored the contract and resumed funding these services, but the defendants have appealed the rulings and the future of these programs remains highly uncertain. The current administration’s policies regarding legal services for unaccompanied children have been the subject of widespread media coverage and public outcry. Such policies and plans (and the way they may or may not depart from prior HHS positions) affect not only the hundreds of unaccompanied children with whom Florence Project and Amica Center work but also affect tens of thousands of unaccompanied children and their families across the country, along with the other legal services providers who work with them. And yet, to date, HHS has not publicly revealed the reasons why it terminated the contract – other than by stating that it was for the government’s “convenience” – nor has HHS revealed its plans to satisfy the statutory and regulatory requirements to provide legal services to unaccompanied children (if such plans exist).