In a federal class action, Davila v. Turner, The Legal Aid Society challenged the City’s policy and practice of assigning single-parent recipients to workfare instead of permitting them to enroll in or continue in education or training programs without assessment of their needs.

The Appellate Division, First Department affirmed the trial court orders in McCain, holding the City, the Department of Homeless Services and the Human Resources Administration in civil contempt and imposing retroactive and prospective nightly fines for violations of court orders requiring the provision of shelter.