In a testament to the persistent advocacy for vulnerable populations, numerous states and cities have engaged in significant legal battles against the federal government to protect the Supplemental Nutrition Assistance Program (SNAP) from drastic cuts and disruptions. These efforts have ranged from challenging a restrictive USDA rule on work waivers to confronting the unprecedented threat of benefit suspension during a government shutdown, highlighting the critical role of state-level action in safeguarding vital food assistance for millions of Americans.
The Supplemental Nutrition Assistance Program, widely known as SNAP or “food stamps,” has served as the bedrock of the country’s response to hunger since 1977, offering crucial nutritional support to millions with limited incomes. Despite its vital role, the program has repeatedly found itself at the center of political and legal disputes, particularly concerning federal attempts to alter eligibility and distribution.
Over recent years, a coalition of states and major cities has taken decisive legal action against the United States Department of Agriculture (USDA) to defend SNAP benefits. These lawsuits underscore a fundamental disagreement over the program’s administration, congressional intent, and the severe implications for those who rely on this aid.
The 2020 Lawsuit: Challenging Restrictions on Work Waivers
In January 2020, a formidable coalition of 15 states and New York City launched a lawsuit against the Trump administration and the USDA. The legal challenge aimed to block a new rule that would drastically limit states’ flexibility in extending SNAP benefits. This rule, slated to take effect on April 1, 2020, sought to restrict the ability of states to waive a three-month time limit on benefits for unemployed individuals aged 18 to 49 who are not disabled or raising children—often referred to as Able-Bodied Adults Without Dependents (ABAWDs)—even in areas with scarce job opportunities.
The proposed rule threatened to eliminate food assistance for nearly 700,000 Americans. For instance, in Oregon, over 21,000 residents faced losing an average of $166-$186 per month in food benefits. Connecticut anticipated approximately 26,000 people, predominantly in economically depressed urban centers like Hartford and New Haven, would lose their benefits, amounting to over $41.5 million annually in lost aid.
Congressional Intent and Administrative Overreach
Central to the lawsuit’s arguments was the claim that the USDA rule directly contradicted the statutory language and the express intent of Congress for the food-stamp program. The 1996 federal welfare reform law, while introducing the ABAWD time limit, also established an exception: states could request waivers for regions with high unemployment or insufficient job opportunities. Congress had reaffirmed this discretion multiple times, most recently in the 2018 Farm Bill, where it explicitly rejected similar restrictions to those later imposed by the USDA.
Attorneys General, including Ellen Rosenblum of Oregon and William Tong of Connecticut, strongly condemned the rule. Attorney General Rosenblum stated, “It is hard to fathom why the federal government wants to punish thousands of adults in some of the most employment-impacted areas of our state — people who may not be able to find jobs — by taking away their access to food.” Attorney General Tong emphasized that the proposal “cruelly and unlawfully punishes the poor, and does absolutely nothing to improve job access.”
The states collectively argued that the new rule violated the Administrative Procedure Act (APA) by being “arbitrary and capricious.” They contended that the USDA failed to provide a reasoned explanation for changing decades-old policy, ignored evidence, and did not adequately consider the significant impacts on states and vulnerable populations. Furthermore, the rule-making process itself was flawed, with the final rule diverging significantly from the proposed rule, thereby denying the public meaningful opportunity for comment.
The Court’s Decision and its Broader Implications
In October 2020, a federal court delivered a significant victory for the coalition, permanently blocking the USDA’s controversial rule. Minnesota Attorney General Keith Ellison announced the triumph, noting that the ruling preserved SNAP eligibility for more than 8,000 Minnesotans and a total of 700,000 Americans. The U.S. District Court for the District of Columbia concurred with the states’ arguments, ruling that the USDA’s rule change:
- Violated the federal rulemaking process: The court found that the USDA’s final rule diverged substantially from its initial proposal, denying adequate public comment, a critical breach of the APA.
- Contradicted statutory language and Congressional intent: The ruling underscored that Congress consistently intended for states to have discretion in determining waiver eligibility based on local economic conditions, a principle the USDA’s rule unlawfully undermined.
- Was poorly reasoned, rendering it arbitrary and capricious: The court determined that the USDA lacked sufficient justification for its policy shift, failed to acknowledge reliance interests, and overlooked the disproportionate impact on marginalized communities.
The court’s 67-page decision also critically observed that the “backdrop of the pandemic has provided, in stark relief, [the] procedural and substantive flaws” of the rule, noting the USDA’s “icily silent” stance on how millions of new SNAP enrollees during the pandemic would be affected.
The Current Threat: SNAP During a Government Shutdown (2025)
The fight for SNAP continued years later, facing a different kind of challenge. In October 2025, 25 states, the District of Columbia, and the governors of Kansas, Kentucky, and Pennsylvania initiated a new lawsuit against the Agriculture Department over the looming suspension of SNAP benefits due to an ongoing government shutdown. This unprecedented situation marked the first time in the program’s 60-year history that federal funding for SNAP benefits was threatened during a shutdown.
With benefits expected to run dry by November 1, approximately 42 million Americans faced losing access to crucial food assistance. The USDA, despite previously acknowledging the use of contingency funds for SNAP during the 2019 shutdown, claimed in 2025 that such funds were “not legally available” without a federal budget. This stance prompted widespread alarm and legal action.
Filed in Massachusetts district court, the lawsuit argues that the USDA is legally obligated under the Food and Nutrition Act to continue providing SNAP benefits using available contingency funds appropriated by Congress. California Attorney General Rob Bonta asserted that the USDA possesses up to $6 billion in contingency funds, sufficient to cover November’s benefits, stating, “They are doing this on purpose. It is deliberate. It is intentional. They have the funds. They’re just not using them.” This new legal battle seeks a temporary restraining order to compel the USDA to maintain benefits, highlighting the immediate and severe impact a lapse in funding would have on countless families nationwide, as reported by NBC News.
Long-Term Implications and State-Federal Dynamics
These legal battles demonstrate the critical role states play in interpreting and enforcing federal programs. While the federal government covers the full cost of SNAP benefits, states co-administer the program on a 50/50 basis, giving them significant insight into local economic conditions and the needs of their populations. The attempts by the federal government to impose restrictive, top-down policies have consistently been met with strong resistance from states arguing for local discretion and a pragmatic approach to welfare.
The legal victories underscore the judiciary’s role in safeguarding administrative processes and upholding congressional intent against executive overreach. The courts’ findings against the USDA for violating the APA and contradicting legislative directives set important precedents for how federal agencies must operate, particularly when impacting millions of Americans’ livelihoods. The ongoing government shutdown litigation further tests the boundaries of executive power and the legal obligations to maintain essential services during political impasses. This highlights how such shutdowns, by impacting programs like SNAP, disproportionately harm vulnerable communities and the broader state economies that rely on these federal transfers, as documented by NBC News.
