Manatt Files Amicus Brief Urging Court to Block HHS Policy Restricting Immigrants’ Access to Health Programs

Manatt filed an amicus curiae brief on behalf of leading public health organizations and scholars in State of New York et al. v. U.S. Department of Justice et al., urging the U.S. District Court for the District of Rhode Island to vacate and enjoin a U.S. Department of Health and Human Services (HHS) policy that restricts immigrants’ access to essential health programs.

The amicus brief was submitted on behalf of the American Public Health Association, the Robert Wood Johnson Foundation, the National Center for Medical-Legal Partnership and the Jacobs Institute of Women’s Health, along with 66 deans, professors and scholars of public health, law and health policy. The amici argue that HHS’s July 2025 notice unlawfully reinterprets the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 by newly classifying long-standing, community-based health programs as “federal public benefits.”

As detailed in the brief, the HHS policy would bar millions of immigrants—including individuals with Temporary Protected Status, asylum applicants, DACA recipients and certain visa holders—from accessing programs Congress designed to serve entire communities regardless of immigration status. Affected programs include the Health Center Program, Head Start, the Title X family planning program and federally funded behavioral health initiatives.

The amici explain that HHS failed to consider extensive public health evidence showing that restricting access to these programs will harm individual and community health, deter eligible immigrants and U.S. citizens from seeking care, increase uncompensated care costs and weaken the broader economy. The brief argues that these failures render the policy arbitrary and capricious in violation of the Administrative Procedure Act.

The Manatt team included Partners and as well as Associates and .

Read the full amicus brief .