Massachusetts v. U.S. Department of Agriculture
Overview
Overview
A coalition of states sued the Trump administration over the suspension of Supplemental Nutrition Assistance Program benefits for November 2025.
The Issue
Issue
Whether the Trump administration had statutory authority under the Food and Nutrition Act to suspend Supplemental Nutrition Assistance Program benefits in November 2025, and whether the suspension violated the Administrative Procedure Act by bypassing required procedures.
The Rules
Rule
Under the Administrative Procedure Act, agency actions must not be arbitrary and capricious; agencies must follow statutory procedures including notice-and-comment rulemaking for substantive policy changes. The Food and Nutrition Act grants USDA authority to administer SNAP but requires compliance with specified administrative procedures.
The Application
Analysis
States allege the USDA suspended SNAP benefits through executive action without notice-and-comment rulemaking or demonstrated statutory authorization, causing immediate harm to millions of beneficiaries and imposing compliance costs on state agencies.
The Conclusion
The parties filed a joint motion to dismiss on April 30, 2026, and Judge Indira Talwani dismissed the complaint without prejudice by stipulation on May 1, 2026, terminating the case in the District of Massachusetts.
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