Victory in Case Challenging Harmful SNAP Rule

Starving people does not help them find jobs, especially during a pandemic. 

Last year, Trump’s USDA finalized an administrative rule that would greatly increase the number of Supplemental Nutrition Assistance Program (SNAP) recipients subject to the time limit, by making it difficult for states to waive these requirements during times of economic recession or high unemployment – a power states have utilized for decades.  

Once the rule was finalized, numerous state attorney generals and Shriver Center Legal Impact Network (LIN) member Legal Aid Society of D.C. filed a lawsuit to block the implementation of the rule, as its promulgation violated the Administrative Procedures Act and other statutes.  

Everyone should have access to enough food to live a healthy life. The rule would have made it more difficult for states to obtain waivers of a requirement that able-bodied adults without dependents work a certain number of hours to remain eligible for benefits. 

Members of the Shriver Center’s Legal Impact Network collaborated on an amicus brief which focused on:  

• Scrutinizing the flawed metrics and data utilized by USDA; 
• Highlighting the impacts of the rule on communities of color; and  
• Rebutting assertions that SNAP Employment & Training programs would be able to adequately serve all the individuals who would need to comply with work requirements.  

Many Legal Impact Network Members contributed to this victory. Legal Aid Society of DC successfully litigated the case and helped rally interested amici. Community Legal Services of Philadelphia and Nebraska Appleseed contributed valuable state-level employment and training data that was integrated into the brief, and Legal Aid Justice Center filed the brief on behalf of members.   

LIN Members Advocates for Basic Legal Equality (Ohio), Center for Civil Justice (Michigan), Colorado Center on Law and Policy, Community Legal Services of Philadelphia, Florida Legal Services, Kentucky Equal Justice Center, Legal Aid Justice Center (Virginia), Legal Services of New Jersey, Mississippi Center for Justice, Nebraska Appleseed, New Hampshire Legal Assistance, South Carolina Appleseed, and Tennessee Justice Center all signed on to the brief along with the Center for Law and Social Policy. Western Center on Law and Poverty and Empire Justice Center also coordinated efforts on regional amicus briefs in support of the plaintiffs. 

On October 18, the district court vacated the rule and concluded USDA violated the Administrative Procedures Act both because the regulation was contrary to law and because USDA did not adequately address the legitimate concerns of over 100,000 commentors regarding the increased costs to state agencies and the disparate impact of the rule on people of color.  

Read the opinion.