Published November 7, 2025

The country is facing an unnecessary, self-inflicted emergency: the Trump administration’s refusal to provide food assistance via the Supplemental Nutrition Assistance Program (SNAP) to millions of Americans despite clear legal authority and available funding. States, municipalities, nonprofits, courts, and advocates have had to step in to protect the nation’s most vulnerable families. 

A Crisis of Political Will 

This is not a capacity problem — it’s a choice. Three separate lawsuits (state attorneys general, a national nonprofit coalition, and a class action case) challenge the administration’s actions. Judges have affirmed that the U.S. Department of Agriculture (USDA) can and must fully fund SNAP using contingency and reserve funds. Instead of complying, USDA issued shifting, complicated guidance that forced states to recalculate benefits — delaying payments, creating administrative chaos, and heightening fear for millions. When ordered to use reserve funds for full benefits, the administration appealed. 

This fight should never have reached a courtroom. Historically, administrations of both parties have used contingency funds, carryover appropriations, and short-term accounting adjustments to maintain benefits during funding lapses. The authority exists; but for the current administration, the will does not. 

Administrative Chaos and Real-World Consequences 

State agencies are bearing the brunt of the administration’s mismanagement. Already struggling with staffing shortages and complex federal reporting requirements, they were forced to recalculate benefits multiple times based on shifting USDA instructions. Each change means new programming, new math, and new delays — all the while families wait in grocery lines with empty cards. 

Retailers, too, face mounting strain. Local grocers and farmers who depend on SNAP sales to sustain their businesses are caught in the uncertainty, unable to plan inventory or staffing. For small stores in rural areas, SNAP participation can be the difference between staying open or shutting down. 

The harm is not theoretical — it is unfolding in real time. Families who missed their benefits at the start of the month are struggling to pay for food, rent, and medication. Nonprofits and food banks have been reporting spikes in demand. All of this chaos was avoidable. 

Ongoing Legal Developments and Next Steps 

On November 6, 2025, the U.S. District Court for the District of Rhode Island ordered the Trump administration to fully fund November SNAP benefits, rejecting USDA’s argument that it lacked authority to do so. That same day, the Department of Justice (DOJ) filed a motion for a stay of the court’s order—seeking to block implementation while it appealed. The trial court promptly denied DOJ’s motion for a stay of the order requiring full SNAP benefit issuance.   

The following morning, November 7, USDA sent formal guidance to all states confirming that it was “working toward implementing full November 2025 benefit issuances” in compliance with the Rhode Island court’s order.  

The notice stated that FNS would complete the necessary processes later in the day to make funds available so that states could transmit their full issuance files to Electronic Benefit Transfer (EBT) processors. Crucially, USDA’s November 7 guidance made no mention of the DOJ’s pending appeal or its motion to stay the order. The agency gave no indication that legal challenges were still underway. In fact, FNS officials verbally reinforced this message in follow-up calls with at least one state agency, assuring them that full benefit issuance was moving forward. This lack of transparency created a false sense of certainty and set states up for operational whiplash when the situation changed only hours later. 

While the guidance may have been performative to avoid contempt of court, it was nevertheless an official federal directive. Acting in good faith, several states followed USDA’s instructions that same day and began transmitting issuance files or releasing full SNAP benefits. Others issued partial payments, with timing and implementation varying by state. These actions were taken in direct compliance with USDA’s written and verbal direction. 

That same day, DOJ filed an appeal with the First Circuit Court of Appeals, again seeking to block the order requiring full SNAP benefit issuance. The Appeals Court denied the request. Within hours, the administration escalated the matter to the U.S. Supreme Court. 

At approximately 9:30 p.m. on November 7, Justice Ketanji Brown Jackson, issued a temporary administrative stay over the weekend, directing the Appeals Court to review the case expeditiously. By that time, roughly half of all states had already transmitted or begun issuing benefits—some fully, others partially, depending on state processing schedules. 

The next day, November 8, USDA issued a late-Saturday night memorandum instructing states that “to the extent States sent full SNAP payment files for November 2025, this was unauthorized,” and ordering them to “immediately undo any steps taken to issue full SNAP benefits.” The memo further warned that “failure to comply with this memorandum may result in USDA taking various actions, including cancellation of the Federal share of State administrative costs and holding States liable for any over issuances.” 

USDA’s failure to provide consistent, timely guidance demonstrates a disregard for the operational realities facing states and how that will impact its error rates. Advocates are urged to share these realities with state and federal elected officials and call on USDA to establish a “hold harmless” period to protect states from penalties resulting from this preventable chaos. 

It’s important to note that USDA has no mechanism to take away benefits that were accurately given. We await and see what the decision of the court will be and we will continue to closely monitor developments as they unfold. Click on the hyperlinks to view the updated timeline and state tracking. 

Who SNAP Serves — and Why That Matters 

USDA’s most recent participation report, fiscal year (FY) 2023, underscores what advocates know well: 

  • Vulnerability: 39 percent of participants are children; 20 percent are older adults; and 10 percent are people with disabilities. 
  • Deep poverty: 73 percent of participating households have gross income at or below the federal poverty line ($27,750 for a family of four in FY 2023). 
  • Working households: Nearly one-third of SNAP households have earnings, and among those with children, 55 percent have earnings. On average, SNAP households gross monthly income is $1,059,and their net income is $527. In addition, FRAC’s analysis of the 2018–2023 American Community Survey showed that 80 percent of SNAP households in the U.S. include at least one working individual, which underscores that SNAP primarily supports working families struggling to make ends meet. 
  • Modest benefits: The average benefit is about $6 per person per day; 64 percent of households receive less than the maximum allotment. 

SNAP benefits can only be used for food, but by covering part of a family’s grocery budget, it frees up limited cash for rent, utilities, medicine, and transportation. In other words, SNAP is both a nutrition assistance program and a stabilizer of household finances. It prevents hunger and helps families meet other essential needs. 

The Larger Policy Context: H.R. 1 

While states navigate shutdown-driven confusion, they are also being compelled to implement the most sweeping SNAP cuts in history under the budget reconciliation law (H.R. 1), signed July 4, 2025. The law: 

  • Shifts costs to states and counties, reducing the federal share of administrative funding to 25 percent by FY 2027, and for the first time, requiring states to pay a portion of benefits beginning in FY 2028, tied to administrative error rates rather than fraud. 
  • Expands time limits and work requirements, including older adults up to 65, caregivers of teens, veterans, unhoused individuals, and youth aging out of foster care — despite decades of evidence that these rules do not increase stable employment. 
  • Erodes benefit adequacy by requiring future updates to the Thrifty Food Plan to remain “cost-neutral,” ensuring benefits can no longer keep pace with rising food prices. 
  • Defunded SNAP-Ed, defunding community nutrition education programs that support health, prevention, and partnerships between local agencies and schools. 

Together, these provisions shift costs and responsibility to the very governments least equipped to bear them. They multiply administrative complexity, heighten state error rates, and all but guarantee future funding shortfalls. The shutdown chaos is a preview of what is to come — a demonstration of how policy design choices translate directly into household hardship and local economic pain.  

Data Backslide: Policy by Blindfold 

At the same time, USDA’s move to terminate the CPS Food Security Supplement — the nations only annually fielded, nationally representative measure of adult and child food insecurity with state-level estimates — will prevent tracking of the impact these polices will have on hunger. Ending the CPS-FSS without a proven replacement undermines accountability just as policy changes intensify. History shows that when credible data disappears, hardship is easier to deny and ignore. 

The Cost of Inaction 

The consequences are clear and measurable. Every day of delay in issuing benefits translates into billions of dollars withheld from families and local economies. Every expansion of time limits means more working adults and caregivers losing access to food. Every cut to data and oversight makes it harder to prove what communities already know — that hunger is growing, not shrinking. 

SNAP has always been more than a nutrition program; it is a pillar of public health and economic stability. It reduces poverty, strengthens local retailers, and improves health outcomes for children, veterans, and older adults. Undermining SNAP does not save money; it shifts costs to hospitals, food banks, and city governments already stretched thin. 

During this moment of preventable crisis, the nation faces a simple question: Will we allow political gamesmanship to starve families in the wealthiest country on Earth or will we choose the moral and practical path of feeding our people? 

The courts have spoken. The money and resources (SNAP) exist. What remains to be seen is whether the administration will find the will to act.