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Fact check: Which state governments or agencies legally challenged the Trump administration's SNAP eligibility rule and what outcomes occurred?
Executive Summary
Two distinct waves of legal challenges confronted the Trump administration’s SNAP eligibility and work‑requirement changes: a broad multi‑state coalition sued to block suspension of benefits amid the 2025 government shutdown, and an earlier coalition of states and cities successfully challenged a 2020–2021 USDA final rule expanding work requirements and limiting state waivers. Plaintiffs included at least 25 states and the District of Columbia in the 2025 litigation and 19 states plus D.C. and New York City in the earlier challenge; courts have issued mixed but significant relief, including nationwide blocks of the work‑requirement rule and active litigation seeking to maintain SNAP funding during the shutdown [1] [2] [3].
1. Who loudly filed suit — and why the mix of state and city plaintiffs matters!
The litigation landscape shows two clusters of plaintiffs and two different legal targets. In late October 2025, 25 states and the District of Columbia sued to stop the administration from suspending SNAP benefits during a federal funding lapse, arguing the USDA cannot stop benefits while funds remain [1] [4]. Earlier litigation challenged a USDA final rule that would have narrowed time‑limit waivers and expanded work requirements; that suit was brought by 19 states, the District of Columbia and the City of New York, contending the rule violated federal statute and administrative procedure [5] [2]. The participation of states and large cities signals both federalism and urban policy concerns: states challenge agency prerogatives that affect budgetary and administrative responsibilities, while cities emphasize direct service impacts on residents.
2. What courts have done so far — concrete outcomes and judicial posture
Judges have provided substantive relief in the earlier challenge and taken active steps in the 2025 shutdown suits. A U.S. District Court in the District of Columbia struck down the USDA work‑requirement rule, effectively blocking its enforcement nationwide, finding the rule legally defective [6] [2]. In October 2025, federal judges in other venues considered motions to compel the administration to continue SNAP funding during the shutdown; one Boston judge indicated she would likely order continued funding while motions were pending, and litigation sought temporary restraining orders and injunctions to maintain benefits through November [7] [4]. Courts have thus both invalidated regulatory changes and used equitable powers to preserve SNAP operations pending resolution, underscoring judiciary influence on federal benefits administration.
3. Local governments and nonprofits join the fray — litigation broadened beyond states
Beyond state attorneys general, local governments, nonprofits, and legal aid organizations have filed suits challenging separate USDA actions. In New York City, The Legal Aid Society sued the USDA for terminating a waiver that had shielded NYC SNAP recipients from additional work requirements, arguing the termination unlawfully exposed roughly 100,000 recipients to eligibility changes [8]. A nationwide coalition of local governments and advocacy groups also sued to block the administration’s suspension of SNAP, framing the issue as a mass public‑health and governance emergency affecting over 42 million program participants [9]. These filings indicate multi‑level resistance that combines legal strategy with political and service‑delivery assertions, broadening factual records for judges to consider.
4. Conflicting narratives and legal theories — what plaintiffs argued and how the government responded
Plaintiffs advanced two principal legal theories: first, that USDA lacked statutory authority to implement abrupt suspensions or to terminate long‑standing waivers without notice and proper rulemaking; second, that administrative procedure and federal funding statutes require continuity of benefits while appropriations remain available. Defendants argued executive and agency discretion to manage program eligibility and prioritize funding, especially during a shutdown. Courts have scrutinized statutory text and administrative record, and where judges found agency action arbitrary or beyond delegated authority, they enjoined enforcement [2] [3]. The 2025 suits over benefit suspension hinge on whether USDA can prudently stop benefits during a lapse, and judges have been receptive to emergency relief to avoid mass deprivation.
5. Broader implications — policy, politics, and what to watch next
The litigation produced immediate policy effects: nationwide blockage of the work‑requirements rule curtailed long‑term regulatory change, while shutdown‑era litigation has aimed to preserve benefits for millions in the short term [2] [1]. These outcomes illustrate how courts act as a check on agency regulatory moves and crisis‑period executive actions. Watch for appellate filings and possible stay requests that could reshape relief, and for state administrative responses as they plan budgets and casework under court orders. Stakeholders should monitor docket activity and injunction language closely because subsequent appeals or orders could rapidly alter who receives benefits and under what eligibility criteria [3] [4].