Hall v. U.S. Department of Agriculture

Background

The plaintiffs, Robin Hall and Steven Summers, challenged the USDA’s interpretation and implementation of Section 2302(a)(1) of the Families First Coronavirus Response Act. That provision authorizes the USDA, upon a properly supported request from a state agency, to provide emergency Supplemental Nutrition Assistance Program (SNAP) allotments to address temporary food needs, up to the applicable maximum monthly allotment for the household size.

SNAP provides monthly benefits to eligible low-income households. Households with little or no income may receive the maximum monthly allotment. For households with income, the regular monthly allotment is reduced based on income. The USDA issued guidance stating that a household’s emergency allotment could not raise its combined regular and emergency benefits above the applicable maximum. Under that guidance, households already receiving the maximum regular allotment were not eligible for additional emergency benefits.

California’s Department of Social Services initially proposed providing an emergency allotment to SNAP households regardless of whether they already received the maximum benefit. The USDA rejected that proposal as inconsistent with its guidance. California then submitted a revised request seeking benefits that would raise households’ regular allotments to the maximum, and the USDA approved that request for March and April 2020. California later requested an extension for May. California did not join the lawsuit or file its own action against the USDA.

The plaintiffs asserted that the USDA’s interpretation was beyond its statutory authority and arbitrary and capricious, and they sought a declaration on that basis. They also moved for class certification and for a preliminary injunction covering California SNAP recipients who received, or would receive, the maximum monthly benefit.

The requested injunction

The plaintiffs asked the court to prevent the USDA and the Secretary of Agriculture from denying an otherwise appropriate California request under Section 2302(a)(1) merely because the request would provide emergency allotments to households already receiving the maximum monthly benefit.

The court characterized the requested relief as a mandatory injunction. A mandatory injunction requires a party to take action and changes the existing situation, rather than merely preserving it while a case proceeds. Because mandatory injunctions are particularly disfavored, the plaintiffs had to meet a demanding standard.

Court’s analysis

To obtain the injunction, the plaintiffs had to show a clear likelihood of success on the merits, likely irreparable harm without an injunction, that the balance of equities favored them, and that an injunction served the public interest. The court focused on the likelihood-of-success requirement and held that the plaintiffs had not met it.

The plaintiffs argued that the statutory phrase limiting emergency allotments to an amount “not greater than the applicable maximum monthly allotment” applied only to the emergency allotments themselves. Under their reading, households already receiving the maximum regular benefit could receive additional emergency allotments during the pandemic.

The court found that the plaintiffs’ reading had some persuasive force but concluded that the statute was not unambiguous. It considered Section 2302 in the broader context of SNAP, including the program’s definition of the maximum monthly allotment as the amount needed to feed a household for one month. The court reasoned that Congress could have intended the emergency allotments to raise households that were receiving less than the maximum up to that maximum, particularly in response to unstable employment and lost income during the pandemic.

The court also considered practical and budgetary information. It noted that Congress had not specifically appropriated funds for SNAP emergency allotments in the Families First Coronavirus Response Act, that SNAP allotments were subject to annual appropriations, and that the USDA estimated different costs for the competing interpretations. The court further noted later congressional actions and proposals that, in its view, cast additional doubt on the plaintiffs’ interpretation.

The court acknowledged that the plaintiffs’ position was compelling as a matter of fairness and that COVID-19 had increased food insecurity. But it held that policy choices about how to distribute assistance during the crisis belonged to Congress, not the court. The plaintiffs therefore had not shown that their interpretation was the only reasonable reading of Section 2302(a)(1).

The court also expressed reservations about redressability, which asks whether the requested relief is likely to remedy the plaintiffs’ injury. The plaintiffs could not directly request emergency allotments from the USDA; California would have to renew a request and decide whether to provide the allotments. Because California was not a party and had not stated what it would do if the injunction were granted, the court found that any resulting benefit appeared speculative. The court did not conclusively decide that issue because the plaintiffs’ failure to show a clear likelihood of success was dispositive.

Disposition

Judge Haywood S. Gilliam, Jr. denied the plaintiffs’ motion for a preliminary injunction. The court also advanced the case management conference to June 30, 2020, and directed the parties to discuss an expedited plan for resolving the case on its merits, including the pending class-certification motion. The order did not finally resolve the plaintiffs’ underlying statutory claims.