A federal judge ordered the Trump administration on Thursday to restore funding to AmeriCorps volunteer service programs in two dozen states, finding that the government’s efforts to dismantle the independent agency likely violated federal administrative law.

Baltimore-based U.S. District Judge Deborah Boardman granted a preliminary injunction sought by a coalition of 24 Democratic states, which sued in response to the Department of Government Efficiency (DOGE) cutting AmeriCorps’ funding by $400 million and terminating about 85% of its workforce. The staffing and funding cuts were part of the administration’s ongoing efforts to reduce the size of the federal bureaucracy.

In the 86-page order, Boardman reasoned that the administration’s abrupt dismantling of AmeriCorps — specifically, the cutting of millions in funding appropriated by Congress — violated the Administrative Procedures Act (APA). She wrote that the agency’s “failure to engage in notice-and-comment rulemaking before closing AmeriCorps programs” was “not in accordance with the law.”

When Congress appropriated funding to AmeriCorps last year, it included a requirement that “any significant changes to program requirements, service delivery or policy” for the agency can be made “only through public notice and comment rulemaking.”

When the government, on April 25, 2025, closed hundreds of AmeriCorps service programs across the country “in one fell swoop” and ordered them to “cease all award activities,” it caused “significant disruptions in the delivery of services,” Boardman wrote.

“By law, the agency could only make those changes through public notice-and-comment rulemaking,” the judge wrote. “Because the agency did not do so, the States have shown a likelihood of success that the agency actions were contrary to law, arbitrary and capricious, and without observance of procedures required by law, in violation of the APA.”

Congress mandated such a method because it “ensures that the public gets a meaningful chance to comment on decisions that affect their communities and the volunteers who serve them,” according to Maryland Sen. Barbara Mikulski, the principal author of the amendment.

Boardman, who included an excerpt from Mikulski’s comments on the amendment in her order, said the current situation was “exactly” what the amendment was meant to prevent.

“The catalyst for the notice-and-comment requirement was to prevent AmeriCorps from pulling the rug out from under volunteer organizations and the communities they serve — exactly what occurred here when the agency ‘acted behind closed doors’ to make a change in service delivery and ‘eliminated support for long-standing, successful volunteer programs’ without affording the public the opportunity to comment “on decisions that affect [their] communities and the volunteers who serve them.”

However, Boardman held that the states do not have standing to challenge the administration’s decision to place about 85% of the agency’s staff on administrative leave or to challenge a mass termination, also known as a “reduction in force” or “RIF.”

The judge reasoned that the alleged harms asserted by the States, such as delayed adjudication of grant applications, were too speculative and did not amount to a “concrete harm” necessary to satisfy the injury-in-fact requirement for standing.