Published June 23, 2026
On June 22, 2026, a federal district court issued a significant ruling in Aragon v. Rollins, holding that the U.S. Department of Agriculture (USDA) exceeded its legal authority when it approved state demonstration projects that restricted what Supplemental Nutrition Assistance Program (SNAP) participants could purchase with their benefits.
The decision invalidates USDA’s approvals of SNAP food-restriction demonstrations in Colorado, Iowa, Nebraska, Tennessee, and West Virginia.
Background
Beginning in 2025, USDA approved an unprecedented wave of state waivers allowing restrictions on certain foods and beverages that SNAP participants could purchase with their benefits. USDA has approved 23 state waivers, each implemented or scheduled for statewide implementation. Together, these approvals marked a major shift in federal SNAP policy.
This shift occurred alongside broader federal policy changes affecting low-income households and state budgets. The July 2025 budget reconciliation law (H.R. 1/OBBBA) reduced federal SNAP and Medicaid access and spending by approximately $187 billion and $911 billion over 10 years, respectively. In Medicaid, to partially offset the impact in rural states, H.R. 1 created a $50 billion Rural Health Fund, which covers only about one-third of the projected $137 billion in rural Medicaid cuts over the same period and approximately 5 percent of total Medicaid reductions nationwide. The Trump administration also promoted state applications for SNAP food restriction waivers as a “positive factor” in securing access to this limited rural health funding, effectively linking SNAP policy changes to states’ efforts to backfill Medicaid losses.
That approach departed sharply from longstanding USDA practice. Before 2025, Democratic and Republican administrations, including the first Trump administration, denied state waiver requests to restrict SNAP purchases. Those denial letters cited concerns about stigma, operational feasibility, state agency challenges, interstate interoperability, retailer burden, and the lack of rigorous evaluation designs for credible evidence.
The waivers challenged in this case shared a common structure. Each state requested authority to waive the federal definition of “food” and replace it with a more restrictive, state-specific definition. The projects applied statewide to all SNAP participants and retailers, with no medical exemptions and no ability for participants to opt out.
Five SNAP participants from Colorado, Iowa, Nebraska, Tennessee, and West Virginia then challenged USDA’s approvals in federal court.
The Plaintiffs’ Challenge
The plaintiffs claimed that USDA overstepped its authority under the Food and Nutrition Act and failed to follow the required administrative procedures in approving the demonstrations. The court found that the plaintiffs had the right to sue as the restrictions would significantly impact their health, finances, and daily routines.
One plaintiff with diabetes explained that juice boxes and small cans of soda are often the quickest and most reliable way to address dangerous drops in blood sugar. Another plaintiff with kidney disease relied on products such as Pedialyte and Gatorade to maintain hydration and manage his condition.
A Nebraska plaintiff with chronic insomnia and severe allergies relied on low-sugar energy drinks recommended by his dietitian because he could not safely consume coffee or tea. In Tennessee, a mother caring for a daughter with autism and avoidant/restrictive food intake disorder (ARFID) explained that many of her daughter’s limited “safe foods” would no longer qualify for purchase under the state’s proposal.
The court recognized that these households already live on extremely limited budgets. Requiring them to pay full price for items previously covered by SNAP would reduce the practical value of their benefits and create concrete financial and health-related harms.
Why the Court Ruled Against USDA
USDA approved the projects under Section 17(b) of the Food and Nutrition Act, codified at 7 U.S.C. § 2026(b). That provision allows the Secretary of Agriculture to conduct pilot projects designed to test changes that might “increase the efficiency of the supplemental nutrition assistance program and improve the delivery” of SNAP benefits.
The statute also limits these projects to specific purposes, including improving program administration; increasing participant self-sufficiency; testing innovative welfare reform strategies; or allowing greater conformity with other public assistance programs.
The court concluded that the food-restriction demonstrations did not fall within any of those categories.
As the court explained, those objectives fall under a different section of the law.
The Importance of Section 2026(k)
A key part of the decision focused on Section 2026(k) of the Food and Nutrition Act.
Congress created Section 2026(k) specifically to authorize pilot projects aimed at “using [SNAP] to improve the dietary and health status” of participants and “to reduce overweight, obesity … and associated co-morbidities.”
The court noted that the goals described by USDA and the states closely matched the purpose of Section 2026(k). USDA’s own materials described the demonstrations as efforts to promote healthy eating, improve nutrition, and address obesity and chronic disease.
However, Congress did not simply authorize health-focused demonstrations. It also established a more rigorous framework for them.
Section 2026(k) requires projects to be evaluated against publicly available criteria, incorporate evidence-based strategies, include rigorous outcome evaluations, and collect data to assess effectiveness. The statute also identifies the types of interventions Congress envisioned, including incentives to purchase fruits and vegetables, increased access to healthy foods, and encouragement for retailers to stock more nutritious options.
The court concluded that USDA effectively bypassed these requirements by relying instead on Section 2026(b).
As the court observed, Congress specifically authorized incentive-based strategies to encourage healthier eating. It did not authorize USDA to redefine what qualifies as food under SNAP or eliminate entire categories of otherwise eligible foods from the program.
This distinction is particularly important because the approved state demonstrations lacked the rigorous evaluation, evidence base, or participant-focused design contemplated by Section 2026(k). Our review of the approved projects among all 23 states found significant weaknesses in evaluation methodologies, outcome measures, implementation planning, and participant communication strategies. Although states submitted evaluation and communication plans, they all lacked the rigor needed to demonstrate whether restrictions would improve health outcomes, reduce obesity, or avoid unintended consequences for participants.
The court’s decision reinforces the principle that, if nutrition-focused demonstrations are pursued in the future, they must meet the higher standards established by Congress.
USDA Also Failed to Follow Required Procedures
The court identified a second legal problem with USDA’s actions.
Federal regulations require USDA to publish a notice in the Federal Register at least 30 days before implementing a demonstration project likely to have a significant impact on the public. The notice must explain the project’s purpose and operational procedures.
USDA failed to publish those notices, arguing that the projects would not have a significant impact on the public.
The court rejected that argument and noted that the projects applied to the entire state SNAP populations and thousands of retailers, affected what participants could purchase with their benefits, required extensive retailer modifications, and were repeatedly described by USDA as “historic,” “novel,” and “unprecedented.”
The court concluded that projects of this scale would clearly have a significant impact on the public and therefore required formal notice under USDA’s own regulations.
What Advocates Should Know and Do
The court granted summary judgment, meaning it decided the case without a trial because the relevant facts were not meaningfully disputed and the plaintiffs were entitled to judgment as a matter of law. The court ordered that the pilot projects in Colorado, Iowa, Nebraska, Tennessee, and West Virginia may not proceed.
The ruling reaches beyond SNAP food restrictions: it reaffirms that federal agencies must act within the authority Congress grants and follow the procedures the law requires.
The decision does not bar future efforts to improve nutrition and health outcomes for SNAP participants, including incentive programs such as Double Up Food Bucks. It does, however, make clear that any future demonstrations must have clear legal authority, rigorous evaluation, and safeguards to minimize unintended harm to households, retailers, and state agencies.
Although the ruling is significant, it does not end the debate over SNAP food restrictions.
- The decision applies only to the five-state demonstrations challenged in Aragon v. Rollins. Other approved state restrictions remain in effect unless USDA withdraws them or a court separately invalidates them. USDA may also appeal. Nebraska may present additional issues because it requested another waiver while the litigation was pending.
- The ruling also has implications beyond the five plaintiff states. Other approved SNAP restriction demonstrations relied on the same USDA process, the same statutory authority, and many of the same legal and procedural assumptions the court rejected. For that reason, the decision may provide a roadmap for future challenges.
- In states that have not yet implemented restrictions, policymakers should weigh whether to proceed while litigation may continue and additional USDA guidance may follow. State agencies and legislatures should review the ruling carefully and assess the legal, operational, and fiscal risks of implementation.
- In states that have already implemented restrictions, advocates should document how the policies affect SNAP participants, retailers, state agencies, and food banks. They should pay particular attention to people with disabilities, chronic health conditions, specialized dietary needs, and caregiving responsibilities.
- Advocates should also track implementation costs. Retailers have modified point-of-sale systems, updated compliance procedures, trained staff, and navigated differing state requirements. State agencies have spent significant resources on implementation, monitoring, retailer support, and participant communications. These costs come at a difficult time: more than 4 million people have already lost SNAP benefits because of recent federal policy changes; states will assume greater SNAP administrative cost responsibilities beginning in October; and the current Republican Senate farm bill proposal does not relieve states of the new administrative cost shifts or the benefit cost-sharing requirements enacted under H.R. 1.
Given these fiscal pressures, states should carefully consider whether food restriction demonstrations are a sound use of limited administrative resources.