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On March 18, 2025, a federal judge temporarily ordered the EPA and Citibank to give three nonprofits access to grant funds held at the bank, rejecting the EPA’s explanations as inadequate at that stage. That was emergency relief, not a final judgment: a D.C. Circuit panel later vacated a separate preliminary injunction, and the full circuit subsequently agreed to rehear the case.
Which grants and nonprofits were involved?
The grants came through the Greenhouse Gas Reduction Fund, established by the Inflation Reduction Act. Under the National Clean Investment Fund, grant money was to be held at Citibank under agreements with the grantees. The three organizations that sought the March emergency order were:
| Nonprofit | Award listed in the district court opinion |
|---|---|
| Climate United Fund | $6.97 billion |
| Coalition for Green Capital | $5 billion |
| Power Forward Communities, Inc. | $2 billion |
The amounts are those listed for these plaintiffs in the 2025 U.S. District Court for the District of Columbia opinion. They are not the broader program figure sometimes used in later appellate discussion: the D.C. Circuit opinion described a $16 billion award program for five nonprofits.
Why did the nonprofits seek emergency relief?
In mid-February 2025, the organizations tried to draw on their accounts but could not access the funds. The EPA sent termination notices in March, and the nonprofits sued the agency defendants and Citibank, seeking court orders while the litigation proceeded.
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The termination letters referred to ongoing investigations and allegations of waste, fraud, abuse, and conflicts of interest. On the preliminary record, Judge Tanya S. Chutkan found the explanations lacked specific information, factual support, or individualized reasoning. Her brief characterization of the letters was: “This is insufficient.”
The district court also found that the nonprofits faced imminent, irreparable harm and had shown a substantial likelihood of success. Those were preliminary assessments supporting emergency relief—not final findings that no misconduct occurred, nor a final resolution of the nonprofits’ claims.
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What did the March order require?
The March 18 order was a temporary restraining order (TRO). It required the EPA and Citibank to give the nonprofits access to funds in their accounts while the court considered the dispute. In practical terms, it was a temporary intervention in the handling of the grant accounts; it did not decide every issue in the lawsuits or finally resolve the legality of the EPA’s actions.
The distinction matters because the later appeal concerned a preliminary injunction entered by the district court after the TRO. The TRO and that later injunction were separate steps in the case, and the appellate court’s September ruling vacated the later injunction.
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What did the appeals court decide?
On September 2, 2025, a divided D.C. Circuit panel vacated the district court’s preliminary injunction. Its central conclusion was about the proper court to hear the claims: it viewed the grantees’ regulatory and arbitrary-and-capricious claims as essentially contractual, placing them within the exclusive jurisdiction of the Court of Federal Claims. The panel also rejected the constitutional claim and concluded that the equities favored the government.
The panel wrote, “We conclude the district court abused its discretion in issuing the injunction.” It also said the grantees were unlikely to succeed because their claims were essentially contractual and jurisdiction lay exclusively in the Court of Federal Claims.
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This was a jurisdictional and procedural ruling, not a finding that every EPA allegation was proven. The panel’s conclusion about where the dispute belonged should not be recast as a factual determination about waste, fraud, abuse, or conflicts of interest.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Did the September ruling end the case?
No final end to the dispute is established by the procedural history summarized here. Congress later repealed the statutory provision authorizing the Greenhouse Gas Reduction Fund and rescinded unobligated balances. The panel said the appeal was not moot because the disputed funds remained at Citibank and remained obligated.
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The full D.C. Circuit later agreed to rehear the case en banc, meaning the case would be considered by the court as a whole rather than only by the three-judge panel; the court held argument. The materials available for this account do not establish an en banc disposition. Accordingly, the September panel opinion is an important appellate ruling, but it should not be presented as the final word of the full court.
What this means for personal-finance readers
This litigation concerns federal grant funds and the legal relationship among the EPA, the nonprofit recipients, and Citibank as the institution holding the accounts under the grant agreements. It is not a ruling about ordinary Citibank customer deposits, consumer access to bank accounts, or a change to personal banking protections. The practical stakes described in the orders were whether these nonprofits could access their grant funds while the case proceeded.
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