The GGRF lawsuit is a consolidated legal fight over the Trump administration’s March 2025 termination of roughly $20 billion in Greenhouse Gas Reduction Fund grants, money Congress appropriated through the Inflation Reduction Act and that the EPA had already awarded and transferred to Citibank accounts for eight nonprofit recipients. Grantees sued to unfreeze the funds and reverse the terminations; the government has fought to move the dispute into the Court of Federal Claims, where only money damages are available. As of mid-2026, the full D.C. Circuit is weighing the case after Congress repealed the program’s statutory basis in July 2025, and the money remains frozen at Citibank.
The Program at the Center of the Case
The Greenhouse Gas Reduction Fund was a $27 billion program created by the Inflation Reduction Act in August 2022 and administered by the EPA under the Clean Air Act. It ran through three competitive grant tracks: the $14 billion National Clean Investment Fund for national nonprofit “green banks,” the $6 billion Clean Communities Investment Accelerator for community lenders in low-income areas, and the $7 billion Solar for All program for states, tribes, and nonprofits expanding residential solar.
The EPA announced final selections in April 2024 and finalized the awards by that August. The three largest National Clean Investment Fund grants went to Climate United Fund (nearly $7 billion), the Coalition for Green Capital ($5 billion), and Power Forward Communities ($2 billion). Five organizations received Clean Communities Investment Accelerator awards, including Inclusiv ($1.87 billion) and the Justice Climate Fund ($940 million). All of the money for those two programs had been transferred to Citibank accounts by September 30, 2024, with Citibank serving as the Treasury Department’s financial agent.
Why EPA Terminated the Grants
In February 2025, the FBI recommended that Citibank place an administrative freeze on the grantee accounts. On March 11, 2025, EPA Administrator Lee Zeldin formally terminated the $20 billion in grants awarded under the National Clean Investment Fund and the Clean Communities Investment Accelerator. His termination letters cited “substantial concerns regarding program integrity, the award process, programmatic fraud, waste, and abuse, and misalignment with the agency’s priorities.” Zeldin called the program “riddled with self-dealing and wasteful spending” and said the EPA had referred matters to its Office of Inspector General. The agency also pointed to Justice Department and FBI investigations, and characterized the Biden administration’s decision to hold funds at Citibank as an effort to reduce federal oversight.
Grantees pointed out that the EPA had not identified specific instances of waste, fraud, or abuse, and said the agency’s objections went to program structure rather than actual misconduct. By May 2025, New York Times reporting indicated that the Justice Department’s criminal investigation had “failed to find meaningful evidence of criminality by government officials” and had “yet to yield any strong evidence of criminal conduct” by recipients either. The FBI and EPA Inspector General investigations likewise did not produce evidence of fraud.
Who Sued and What They’re Arguing
Climate United Fund filed the lead case on March 8, 2025, in the U.S. District Court for the District of Columbia, naming Citibank, the EPA, and Zeldin as defendants. The case was assigned to Judge Tanya Chutkan. Climate United’s complaint raised breach of contract claims tied to the account control agreement governing the Citibank funds, Administrative Procedure Act violations, conversion, and constitutional claims under the Fifth Amendment’s Due Process Clause and the Appropriations Clause.
Other grantees followed within weeks. The Coalition for Green Capital sued on March 10, 2025. Inclusiv sued March 31, calling the termination “arbitrary, capricious, and not in accordance with law.” The Justice Climate Fund filed the same day. The Opportunity Finance Network filed April 21, noting that the cancellation affected more than $228 million in awards to 26 organizations across more than 30 states and threatened roughly 5,000 jobs. By mid-April 2025, several of these actions had been consolidated under Climate United Fund v. Citibank.
The Injunction and Its Reversal
On April 15, 2025, Judge Chutkan issued a preliminary injunction barring the EPA and Citibank from effectuating the terminations and ordering Citibank to continue disbursements. The court found that the EPA “failed to provide evidence of GGRF grantee waste, fraud, or abuse” despite weeks to produce it, and held that the agency “lacks the authority to effectively unilaterally dismantle a program that Congress established.”
The D.C. Circuit administratively stayed the injunction on appeal. On September 2, 2025, a divided three-judge panel vacated the injunction outright. The majority held that the district court lacked jurisdiction because the grantees’ claims were “essentially contractual” and belonged in the U.S. Court of Federal Claims under the Tucker Act. The panel treated the grantees’ request as one for “specific performance” of the grant agreements, a remedy the district court could not provide, and said any harm was “readily compensable through damages.” It also rejected the grantees’ separation-of-powers argument and concluded that “the equities strongly favor the government.”
Judge Cornelia Pillard dissented, writing that the EPA had acted “without presenting to any court any credible evidence or coherent reason that could justify its interference with Plaintiffs’ money and its sabotage of Congress’s law.” She warned the ruling likely allowed the EPA to “immediately and irrevocably seize” the money from Citibank.
How the July 2025 Repeal Changed the Case
While the appeal was pending, Congress eliminated the program’s statutory foundation. On July 4, 2025, President Trump signed the One Big Beautiful Bill Act. Section 60002 repealed the Clean Air Act provision creating the GGRF and rescinded the “unobligated balances” of appropriated funds. On August 7, 2025, the EPA formally ended the $7 billion Solar for All program under that authority.
The fight now turns on whether the $20 billion at Citibank was “obligated” or “unobligated.” If obligated, the rescission does not reach it. All $27 billion had been formally obligated to grantees by August 2024, and the National Clean Investment Fund and Clean Communities Investment Accelerator funds had been fully disbursed to Citibank accounts by September 30, 2024. The Congressional Budget Office scored the repeal as saving only $19 million, representing unspent EPA administrative funding, and did not count any of the $27 billion in its estimate. During the House Energy and Commerce Committee markup, then-Subcommittee Chair Morgan Griffith stated for the record that the language “does not close the grants on any obligated funds.” The Trump administration nonetheless argues that the repeal eliminated the EPA’s authority to administer the programs and rendered the money unrecoverable.
Where the En Banc Case Stands
In December 2025, the full D.C. Circuit vacated the three-judge panel’s September ruling and granted rehearing en banc. A partial administrative stay was reinstated: the funds remained frozen at Citibank, but the EPA was barred from taking further steps to effectuate the terminations.
Ten of the court’s eleven judges heard argument on February 24, 2026. Much of the discussion focused on whether the court could still order meaningful relief given the repeal. Judge Neomi Rao asked how a separation-of-powers violation could persist if the underlying statutory program had been repealed: “what is left to enjoin?” The grantees argued that the One Big Beautiful Bill Act rescinded only unobligated balances and could not retroactively extinguish the government’s binding commitments under executed grant agreements. The EPA responded that even assuming the termination was legally questionable, the repeal eliminated any available remedy.
On March 9, 2026, the court ordered supplemental briefs on whether the plaintiffs’ Inflation Reduction Act and constitutional claims still provided “a valid basis to affirm all or part of the preliminary injunction” after the repeal. The grantees pointed to the CBO’s $19 million estimate and the legislative history. The EPA argued the repeal mooted the practical utility of the plaintiffs’ claims. The en banc court has not yet ruled. Legal observers have said the case is likely headed to the Supreme Court whichever way it comes out.
The Separate Solar for All Litigation
The $7 billion Solar for All program produced its own wave of suits after the EPA terminated those grants in August 2025. In October 2025, 22 state attorneys general and the District of Columbia filed Maryland Clean Energy Center v. United States (No. 25-cv-1738) in the Court of Federal Claims, alleging a “clear, unambiguous, and material breach” of grant agreements and arguing the EPA misread the One Big Beautiful Bill Act to reach already-obligated funds. A Virginia case was consolidated with it in February 2026.
A coalition of 23 states also challenged the Solar for All termination in federal district court in Washington state before Judge Tiffany Cartwright. On June 1, 2026, that court ruled the dispute was “contractual in nature” and directed the states to the Court of Federal Claims, tracking the D.C. Circuit panel’s reasoning in the Climate United case.
What’s at Stake on the Ground
The freeze has produced concrete disruption. A major solar development backed by Climate United Fund at the University of Arkansas, projected to save the state’s public university system $120 million in energy costs, is at risk of cancellation. Power Forward Communities, approved for $2 billion, has cut its staff from 30 employees to two and has funded none of its planned affordable-housing renovations. Inclusiv had committed $651 million to 108 credit unions across 27 states and Puerto Rico before disbursements stopped. The Justice Climate Fund paused $247 million in grants affecting projects in 38 states, Washington, D.C., and Puerto Rico, including energy-efficiency retrofits for churches in Georgia and schools in Oklahoma, Tennessee, and Mississippi, and clean-energy projects for small businesses in rural Arkansas.
The government has consistently pushed to route the litigation into the Court of Federal Claims, where grantees would be limited to seeking money damages rather than the injunctive relief that would actually release the frozen funds and let the projects go forward. The $20 billion sits at Citibank in the meantime, neither released to grantees nor returned to the Treasury, while the en banc D.C. Circuit decides whether the executive branch can wind down a congressionally funded program by terminating its grants and then relying on a later repeal to cut off any remedy.