Joseph v. United States

Background

Save More Food Market, which the plaintiffs also called Sav More, is a San Francisco store owned by Joseph. The United States Department of Agriculture permanently disqualified the plaintiffs from participating in the Supplemental Nutrition Assistance Program (SNAP) in September 2019. The agency concluded, based on a data analysis, that SNAP benefit trafficking had occurred. The plaintiffs contested the charge and filed a timely administrative appeal, but the agency denied the appeal and issued a Final Agency Decision upholding the disqualification on February 18, 2020.

Under 7 U.S.C. § 2023(a)(13), a party seeking judicial review of a final SNAP agency decision must file a complaint against the United States within 30 days after receiving the final decision. The plaintiffs acknowledged that they filed more than 30 days after receiving the decision. The government stated that the filing was 36 days late. The plaintiffs asked the court to excuse the delay because the early COVID-19 public-health crisis and stay-at-home orders interfered with their ability to find and retain an attorney.

Issues

The court considered whether the 30-day deadline was jurisdictional, meaning that missing it deprived the court of power to hear the case, and whether the deadline could be equitably tolled. Equitable tolling is a legal doctrine that can extend a filing deadline when an extraordinary circumstance outside a party’s control caused the delay and the party acted with reasonable diligence.

Analysis

The court rejected the government’s argument that the deadline was jurisdictional. Relying on Supreme Court decisions, the court explained that filing deadlines are generally treated as claim-processing rules unless Congress clearly states that missing the deadline eliminates the court’s authority to hear the case. The court found no such clear statement in Section 2023(a)(13). The fact that the deadline relates to the United States’ waiver of sovereign immunity did not change that conclusion.

The court also concluded that the statute did not clearly prohibit equitable tolling. The statute did not contain language expressly barring extensions or requiring inflexible enforcement. The court therefore applied the usual presumption that a non-jurisdictional filing deadline may be equitably tolled.

The court found that the plaintiffs met the requirements for tolling. It treated the public-health crisis and restrictions on civil and personal life, particularly during the early part of 2020, as extraordinary circumstances. The record showed, without meaningful dispute from the government, that Joseph acted with reasonable diligence in trying to hire a lawyer. The court also found that the delay was minimal.

Disposition

The court denied the United States’ motion to dismiss for lack of subject-matter jurisdiction, Dkt. No. 18. It granted the plaintiffs’ motion for equitable tolling and to excuse the late filing of the complaint, Dkt. No. 7. The court stated that it would enter a scheduling order.