The United States District Court for the District of Columbia ruled against the December 2019 final rule from the U.S. Department of Agriculture (USDA) that would limit Supplemental Nutrition Assistance Program (SNAP) benefits for able-bodied adults without dependents (ABAWDs). The court’s decision permanently blocks the Trump administration from implementing the rule.
Judge Beryl Howell found that the administration’s final rule “radically and abruptly alters decades of regulatory practice, leaving States scrambling and exponentially increasing food insecurity for tens of thousands of Americans.” Judge Howell first pointed to the USDA’s failure “to provide sufficient notice of changes adopted in the final rule,” stating there was not sufficient notice of elimination of extended unemployment benefits in the proposed rule text, among other deficiencies. The ruling also characterizes the final rule’s changes to state waiver authority are “arbitrary and capricious” and “not in accordance with the law.” The same is said in regards to the final rule’s adoption of a standard unemployment rate in lieu of previous flexibility states have had in determining whether to support waiver requests.
The ruling also puts the final rule within the context of the COVID-19, stating that the requirements of the final rule would have caused a large number of individuals to lose SNAP benefits in the midst of the pandemic and resulting shutdowns. While the administration’s own estimates of the number of individuals who would have lost SNAP eligibility totaled to 700,000 before the pandemic hit, the Judge notes that SNAP participation has increased by approximately 17 percent since May 2020.