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Is Donald Trump blocking pre-approved contingency funds for SNAP during a government shutdown?
Executive Summary
The core factual finding is that the Trump administration initially instructed the Department of Agriculture (USDA) not to tap a roughly $5–6 billion SNAP contingency reserve to cover regular November benefits during the 2025 government shutdown, but federal judges subsequently ordered the USDA to use those contingency funds to continue SNAP payments; the litigation and conflicting agency documents make clear the administration’s action temporarily halted use of pre‑approved contingency funds until courts intervened [1] [2] [3]. The dispute is legal and procedural, not merely political: it centers on the administration’s statutory interpretation of contingency funds versus multiple prior practices and a judicial ruling overriding the administration’s interpretation [4] [5] [6].
1. How the Administration Announced a Block and What It Said
A USDA memo from late October 2025 announced that the Trump administration would not use a $5 billion contingency reserve to keep SNAP benefits flowing during the shutdown, arguing those funds are legally limited to disaster response and not routine monthly benefits. The memo framed the pause as a legal constraint and shifted responsibility to Congress for reopening appropriations to avoid benefit interruptions, explicitly refusing to treat contingency money as available for regular SNAP operations [1] [5]. Critics pointed to a separate multi‑year USDA shutdown plan that had previously contemplated contingency fund use for SNAP, underscoring a tension between the memo’s legal rationale and agency operational planning documents [5].
2. Court Rulings Forced a Different Outcome
Within days of the memo, federal courts in multiple jurisdictions ordered the USDA to use contingency funds to continue funding SNAP for November, with judges in Massachusetts, Rhode Island, and Michigan finding the administration’s refusal unlawful or otherwise requiring use of the reserve to prevent harm to beneficiaries. The courts gave the administration discretion on whether to fund partially or fully but directed that contingency reserves must be considered and tapped if necessary, affecting tens of millions of beneficiaries and reversing the practical effect of the administration’s memo pending appeals [2] [6] [3] [7]. The rulings required updates and progress notes from the administration and prompted immediate state actions to implement orders [2] [7].
3. Precedent, GAO Findings, and the Historical Record
Multiple analyses and past USDA guidance contradict the administration’s legal position by showing the contingency reserve has been used historically to pay SNAP benefits in shutdown scenarios, including guidance issued during prior administrations and actions in 2018–2019. A report notes that USDA guidance under both Republican and Democratic administrations treated the contingency reserve as available for routine SNAP benefits in shutdowns and that a Government Accountability Office review found funds available to pay benefits, establishing precedent that undercuts the administration’s narrower legal interpretation [4] [5]. This prior practice formed a central argument in the court challenges brought by state attorneys general and governors alleging unlawful suspension of benefits [3].
4. The Practical Impact on Households and State Responses
The administration’s initial refusal to use contingency funds triggered partial payments and reductions for millions of recipients and prompted several states to explore using state funds to bridge gaps. Advocacy groups and Democratic lawmakers warned that withholding contingency funds would leave many households without full November benefits, while the courts’ orders aimed to mitigate immediate hunger risks by compelling federal funding through the reserve. Food banks and state relief programs reported surges in demand, and some states allocated emergency dollars while litigation proceeded, highlighting the tangible human impact behind the legal and bureaucratic dispute [5] [7] [6].
5. What Remains Contested and What to Watch Next
Legal appeals by the federal government were filed after judges ordered use of contingency funds, so the final legal interpretation could change depending on appellate rulings; however, the immediate effect of the judicial orders was to require the use of the contingency reserve for November benefits. The central contested points that could recur on appeal are the statute’s text about permissible uses of the contingency reserve, prior agency practice, and whether a shutdown qualifies as a “disaster” context for the reserve’s use. Observers should watch appellate filings, any updated USDA written guidance, and state compliance reports to track whether court mandates produce full, sustained payments or further litigation [2] [4] [6].