The Legal Aid Society, on behalf of individual petitioners and the Coalition for the Homeless, Neighbors Together, and Women in Need, filed this lawsuit to prevent the City of New York from abruptly eliminating the longstanding Unit Hold Incentive for property owners renting to CityFHEPS voucher holders. The Unit Hold Incentive has long served as a lifeline for unhoused New Yorkers by covering rent while a CityFHEPS voucher application is processed — helping to secure apartments, to shorten shelter stays, and to make the transition to permanent housing possible for thousands of families and individuals each year. In June 2025, Legal Aid secured an injunction staying the City from ending the Unit Hold Incentive until it promulgated new rules.

The Adams administrations’ sudden decision to end the Unit Hold Incentive threatened to slam the door on countless New Yorkers desperately seeking homes. In its ruling, the court made clear that, unless and until the City follows proper rulemaking procedures under the State Administrative Procedure Act, the Department of Social Services is barred from rescinding this critical program. The court rightly recognized that such a move cannot be made without following the law, and that the stakes are far too high for our clients and their families.

In November 2025, Legal Aid and The Coalition for the Homeless submitted a written comment in opposition to related rulemaking.