Testimony of Charisse Lue, Policy and Advocacy Attorney, Brit K. Ruffin, Legal Director, Systemic Advocacy and Litigation, and Joshua Drumming, Policy and Advocacy Attorney, The Washington Legal Clinic for the Homeless
October 8, 2026
Since 1987, the Legal Clinic has worked towards a just and inclusive community for all residents of the District of Columbia–where housing is a human right, housing is a human right, racial justice is a reality, and all people have true and meaningful access to the resources needed to thrive.
For years, The Legal Clinic has provided daily advocacy and legal representation when the Virginia Williams Family Resource Center (“VWFRC”) creates barriers to family shelter access and/or unlawfully denies emergency family shelter to an applicant family.[1] Unfortunately, D.C. residents are subject to VWFRC’s unfair, unlawful, and arbitrary practices that effectively bar access to shelter for the majority of applicants. Data shows that VWRFC has consistently maintained a family shelter denial rate of more than seventy percent (70%). Currently, as of 2026, VWFRC has reached a denial rate of approximately eighty-two percent (82%). VWFRC creates overburdensome standards to deny family shelter applications that are not prescribed in the Human Services Reform Act (HSRA). The HSRA is clear that a family seeking family shelter must only demonstrate that they are D.C. residents and are homeless or at risk of homelessness to qualify for family shelter. D.C. Code § 4-753.02 (a). However, it has become standard practice to request that an applicant provide a letter from a former landlord of a unit in which the applicant no longer has a lease, a copy of a friend’s lease in which they were never a party, or an official letter stating that a unit is not fit for human habitation. These manufactured requirements are not tethered to the law or the reality of homelessness. DHS is asking applicants to accomplish impossible feats to access the most basic human need–shelter.
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The HSRA protects applicants from being deemed ineligible solely because the family cannot produce proof of D.C. residency at the time of the application. D.C. Code § 4-751.02(a-4)(b). It also clearly indicates that it is DHS’ burden to demonstrate, by clear and convincing evidence, that the applicant is not a D.C. resident if the applicant does not have immediate proof. Unfortunately, DHS never attempts to satisfy its own obligation to demonstrate that the applicant is not a resident before it denies family shelter access. D.C. Code § 4-751.02(5)(c-1)(2). Additionally, D.C. protects residents from having to continue occupying units that are a threat to life, health and safety and asserts that the mayor may not deny services to a family that cannot safely inhabit their leased premises. D.C. Code § 4-751.02(b-1)(1)(B).
The HSRA also specifically permits Interim Eligibility placement when eligibility requirements cannot be immediately confirmed. Despite the existing law, DHS regularly refuses to adhere to it. Interim eligibility placement should be routinely offered at VWFRC as the default placement option for emergency shelter applications. Instead, DHS implements its own standards, requiring excessive and unnecessary documentation that guarantees barriers to family shelter access. Then, when DHS denies the families and refuses to offer a shelter placement, it fails to issue denial notices that lists the reason for the denial, as required by the HSRA. On numerous occasions, DHS has required a copy of a birth certificate for admission to emergency shelter and denied the family for not having it readily available on the night that it needs immediate shelter placement. DHS has even required that an emergency family shelter applicant produce documentation from the Department of Buildings that confirms that a unit is unfit. DHS refused to accept pictures and videos of unfit conditions and refused to offer interim eligibility before The Legal Clinic’s intervention.
DHS must develop fair, consistent, transparent and lawful shelter applicant assessment tools that align with the HSRA. Applicants report being required to list the names and phone numbers of family members, neighbors, and friends before an emergency shelter eligibility assessment is even conducted. Applicants seeking our assistance have reported being asked to provide up to nine contacts. After providing contacts, staff call to request that the contacts allow the family to stay with them. The humiliating request and calls do not meet any requirement listed in the HSRA. VWFRC disregards the often stressed or nonexistent contact relationships and disregards the fact that most contacts would have lease violations and risk their own housing stability if they allowed people to stay with them who are not on their lease. Sometimes, applicants report that they are uncomfortable staying with family members or friends that may have previously allowed them to stay temporarily. They have detailed unsafe environments in which they do not want to subject their children. Still, VWFRC will attempt to persuade the contacts to provide shelter to an applicant family, despite the applicant being uncomfortable and VWFRC knowing that placement may only be for a night or two. Some families have reported that their assessment included DHS staff verifying that they had been living in their car by examining their vehicle. VWFRC’s practices violate applicants’ privacy and result in further traumatizing the shelter-seeking family.
DHS boasts of its “prevention and diversion” model, including the Homeless Prevention Program (“HPP”). However, the diversion programs are functioning as constructive denials from shelter placement. There is no transparency as to how the program operates, how shelter applicants are referred, how funds are used, or how it actually provides requested assistance. HPP needs clear regulations and eligibility criteria. DHS’ responses for this hearing include its claim that HPP referrals are not shelter denials. The Legal Clinic emphatically disagrees. Applicants present to VWFRC to apply for emergency shelter, are denied shelter without a notice of denial, have the urgency of their shelter request dismissed, and are referred to other DHS personnel for non-shelter “interventions.” It remains unclear how an applicant family is determined to be suitable for HPP referral instead of receiving the immediate shelter placement in which they applied. A shelter applicant does not have the option to refuse HPP in favor of shelter placement. The Legal Clinic has encountered HPP-referred applicants that were still without safe shelter, despite being denied emergency shelter and referred to HPP. Sadly, it is not difficult to see how DHS consistently maintains its self-reported and alarming family shelter denial rate.
VWFRC staff must be retrained on the HSRA and eligibility rules for shelter access so that families in need of safe shelter can readily access it. Too often, The Legal Clinic assists clients that are subject to staff ignorance of the law and inconsistent application of eligibility criteria. The Legal Clinic has intervened in instances of discrepancies in the eligibility process of a father seeking family shelter with his children as opposed to a mother seeking the same. The Legal Clinic has assisted non-English speakers that have been denied shelter and/or the opportunity to apply for shelter due to a lack of language access or what the language seemingly implied to the VWFRC staff member regarding eligibility. Parents that share child custody and domestic violence survivors are often denied and/or forced to navigate a different eligibility standard than parents that have their children full-time. Parents do not have to have full-time physical custody of their children to access family shelter. Domestic violence survivors do not have to risk exposure or waive safety measures in order to access emergency family shelter with their children. The Domestic Violence Action Research Collaborative (DVARC) released a study and three reports[2] in 2022 that detailed DV survivor experiences with VWFRC from 2018-2019. This Committee should further explore those recommendations and ensure that DHS and VWFRC staff are appropriately trained in survivor-centered and trauma-informed service delivery.
Furthermore, proper protocols must be established to increase the overall quality of customer service at VWFRC, including transparency of processes via the shelter hotline. Families should expect a timely evaluation of their application for emergency shelter and placement, regardless of the method in which they connect with VWFRC. In far too many instances, applicants (and attorneys) report extremely late communication from VWFRC or no follow-up communication at all. The agency and staff designated to help families in one of their most desperate moments must understand and appreciate the significance and impact of a shelter request and denial. VWFRC’s default goal should be to assist families in their time of need, not to create unnecessary barriers to prevent families from accessing shelter.
Lastly, The Legal Clinic has previously testified regarding the disruption to our access to applicants at VWFRC. Historically, our organization has played a critical role in informing denied families of their rights and assisting them in obtaining emergency shelter. Upon VWFRC’s relocation from Rhode Island Avenue to 64 New York Avenue, our staff was prohibited from continuing to do outreach in the VWFRC lobby, severely reducing the number of denied, but eligible, shelter applicants we can help access shelter. While DHS assured D.C. Council that their services would remain just as accessible as they were in their Rhode Island location, our office’s shelter access case numbers beginning in 2025 indicate that this has not been the case. If shelter applicants cannot connect with assistance and are unaware of their rights under the HSRA, particularly during hypothermia season, families will unnecessarily remain in unsafe conditions. This Committee must ensure transparency and accessibility.
The Washington Legal Clinic for the Homeless urges D.C. Council to:
- Amend the Homeless Services Reform Act (HSRA) to require a low-barrier and humane family shelter, including ensuring automatic interim eligibility placement and the reintroduction, passage, and funding of the Housing is Maternal Health Amendment Act of 2024;
- Implement consistent and standardized DHS/VWFRC staff training so that families are not routinely, arbitrarily, and unlawfully denied shelter placements or refused written shelter denial notices;
- Increase reporting and data on access, eligibility, and denials to D.C. shelter services, including for HPP, other diversion programs, and the shelter hotline; and
- Require DHS to permit legal services outreach at the Virginia Williams Family Resource Center (VWFRC).
Appendix
Client Summary #1
According to Client, she and her five children had been homeless and living in their car for over a month. Client applied for family shelter placement but was constructively denied by refusing to continue the assessment claiming that she had to get a letter from a past landlord that the family no longer lived in the unit. Client was given a notice to vacate by the landlord because the unit unfit conditions for human habitability. During the June shelter application assessment staff examined Client’s car to determine if the family was living in it but still denied a family shelter placement. Days later, Client managed to obtain the requested letter from the private landlord, but when she returned to Virginia Williams Resource Center with the documentation that DHS requested staff would not accept the letter because the private landlord did not have a letterhead. The letter included his business address and phone number. Client and her five children returned in mid-July, but this time was denied because staff claimed that she was on her mother’s lease. Client had not lived with her mother since 2019 and was never listed on the lease. The Legal Clinic was able to intervene and, more than a month after the initial shelter application, Client and her five children were able to be placed in family shelter.
Client Summary #2
According to Client, she had sought emergency shelter at the Virginia Williams Family Resource Center (VWFRC) for three to four years and had been repeatedly turned away for different reasons. The most recent denial was based on the alleged fact that she was on her mother’s lease. It had been more than six years since Client lived with her mother and, by her account, she was never on the lease. Although her mother would not provide a copy of the lease, she gave Client a letter confirming that Client was not on it. Client returned with the letter VWFRC told her to bring and was still turned away. VWFRC did not take the steps needed to evaluate the evidence she provided. In good faith, our office took the additional step to contact Client’s mother to obtain documentation that would comply with VWFRC’s unlawful request to demonstrate she was not a leaseholder. Her mother provided the additional documentation and even sent an email message that explicitly stated that neither Client nor her daughter could stay with her. After our office intervened, VWFRC staff called Client around 6 p.m. Instead of placing her and her 11-year-old daughter in emergency shelter, staff told her to return the next morning for “additional assessment.” They gave no explanation, even though both Client and our office had told VWFRC she had no safe place to stay. There was no legitimate question as to Client’s eligibility. When we asked VWFRC what additional information it thought she needed to provide, it sent only general IEP process paperwork that did not answer the question, despite not even admitting Client via IEP at that time.
Client Summary #3
Client was a single mom with 2 toddler-aged children. The whole family had been on her mother’s voucher, but the client’s mother, who had substance abuse issues and strangers in the house, had locked all 3 of them out without warning or access to their belongings. She also blocked client’s phone and took her keys, so they could not access the property at all. Client applied right away at VWFRC and explained the circumstances, but they turned her away because their system showed that the family was on the mother’s voucher. After sleeping with her toddlers in a car for a few days, she called The Legal Clinic. VWFRC’s response to initial outreach was that the client could go into low barrier shelter (without her young children) because, technically, her mother had not removed her 2 toddlers from the unit. The Legal Clinic pointed out that this was an absurd assertion, given the restricted access and unsafe circumstances in the mother’s home. Eventually, DHS relented and placed the family. Without The Legal Clinic’s assistance, the family would not have been placed.
Client Summary #4
Client was evicted and applied for emergency shelter. She had no safe place to go. When she applied for shelter, she was told that she had to list six people that knew her housing history. She told VWRC that she did not have six people to offer, and staff told her that she would be denied as a result. Staff encouraged her to finish the application even though she did not have six people to list, but the supervisor came over and told her that she was already denied, could not finish the application, and to return tomorrow.
Client Summary #5
The Legal Clinic assisted a family who was referred to HPP, despite needing emergency shelter. The family was assigned to a provider. When the family requested emergency shelter, the caseworker told the family that it would take time and that there were no openings in family shelter. The caseworker suggested that the family call 311 for help. When a family calls 311 or presents itself to VWFRC after being referred to HPP, VWFRC simply directs the family to the assigned provider and does not assess them. The family had no safe place to go that night. The family called The Legal Clinic, in tears, because they had no safe place to go, could not get assistance from their HPP provider/DHS, and had kids with health issues. The Legal Clinic assisted in getting the family placed into emergency family shelter because the HPP provider refused to make the referral and VWFRC refused to step in.
[1] See Appendix for summary examples of The Legal Clinic client experiences regarding VWFRC family shelter denials.
[2] “I Could Have Kept That To Myself”: focused on survivors’ disclosure of domestic violence and prioritization of safety when seeking services at Virginia Williams; “She Didn’t Even Look In My Eyes”: focused on survivors’ interactions with staff at Virginia Williams; “I’m Still Homeless”: focused on survivors’ outcomes at Virginia Williams