Update: October 18, 2020 – Victory for SNAP Recipients

The district court granted summary judgment to the plaintiffs in District of Columbia v. U.S. Department of Agriculture and vacated the SNAP time limits rule, holding that USDA violated the Administrative Procedure Act in promulgating the rule. The court found four deficiencies with the process and substance of USDA’s rulemaking: (A) USDA did not provide the public with sufficient notice of the final rule given drastic departures from the proposed rule, (B) USDA’s reduction of states’ flexibility in setting the area for waiver requests from the SNAP time limit was arbitrary and capricious, (C) USDA’s changes to the number of individual discretionary exemptions state agencies may carryover from one year to the next are contrary to law, and (D) USDA failed to adequately consider the costs for states and the disparate impact the proposed rule would have on people of color, women, and people with disabilities.


On July 8, 2020, NWLC joined the Lawyers’ Committee for Civil Rights Under Law in submitting an amicus brief in District of Columbia v. U.S. Department of Agriculture. The case opposes USDA’s draconian rule that would take critical food assistance away from at least 700,000 unemployed and underemployed people, and possibly more because of the COVID-19 pandemic and recession. The amicus brief describes how the rule will have disproportionate impacts in ways that harm women of color, as well as people of color of all genders.