Hall v. United States Department of Agriculture, No. 20-16232 (9th Cir. 2020)
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As part of its response to the COVID-19 pandemic, Congress enacted the Families First Coronavirus Response Act (Families First Act), which provides for emergency assistance to households participating in the Supplemental Nutrition Assistance Program (SNAP).
The Ninth Circuit affirmed the district court's order denying a motion for a preliminary injunction brought by a putative class of Californians, who normally receive the maximum monthly allotment of SNAP benefits, seeking to bar the USDA from denying California's request under section 2302(a)(1) of the Families First Act to issue emergency allotments to households already receiving maximum SNAP benefits. After determining that plaintiffs had Article III standing, the panel held that the USDA, which administers SNAP, correctly interpreted the statute by concluding that it allows households receiving less than the maximum monthly allotment of SNAP benefits to be brought up to the maximum but does not permit those already receiving the maximum to be given any additional benefits. When the panel examined the Families First Act as a whole, as well as other statutes addressing emergency SNAP benefits, three considerations lead it to conclude that the government's reading of section 2302(a)(1) is more consistent with the overall statutory scheme. Therefore, because plaintiffs were unlikely to succeed on the merits of their claims, the district court did not abuse its discretion in denying a preliminary injunction.
Court Description: Supplemental Nutrition Assistance Program The panel affirmed the district court’s order denying a motion for a preliminary injunction brought by a putative class of Californians, who normally receive the maximum monthly allotment of Supplemental Nutrition Assistance Program (“SNAP”) benefits, seeking to bar the U.S. Department of Agriculture (“USDA”) from denying California’s request under section 2302(a)(1) of the Families First Coronavirus Response Act to issue emergency allotments to households already receiving maximum SNAP benefits. In response to the COVID-19 pandemic, Congress enacted the Families First Act, which provided for supplemental SNAP benefits. The USDA, which administers SNAP, concluded that the statute allowed households receiving less than the maximum monthly allotment of SNAP benefits to be brought up to the maximum but did not permit those already receiving the maximum to be given any additional benefits. USDA rejected, as contrary to its guideline, California’s request that all SNAP households in the State receive an extra $60 per person, per month. HALL V. USDA 3 The panel held that plaintiffs had Article III standing. The panel held that plaintiffs satisfied the redressability requirement by submitting a declaration from a California official stating that if the court entered a favorable injunction, California would renew its request for emergency benefits for households receiving the maximum regular monthly benefit. The panel rejected plaintiffs’ contention that the plain language of section 2302(a)(1) foreclosed USDA’s position that SNAP households that already receive the maximum monthly allotment were not eligible for emergency allotments. The panel held that USDA’s interpretation of section 2302(a)(1) was not subject to deferential review under Chevron. The panel further held that the agency had the better reading of the statute without regard to any principles of deference, and the panel need not consider whether the deference prescribed in Skidmore v. Swift & Co., 323 U.S. 134 (1944), applied here. The panel proceeded to construe the statute de novo. Examining the Families First Act as a whole, as well as other statutes addressing emergency SNAP benefits, the panel held that three considerations led it to conclude that the government’s reading of section 2302(a)(1) was more consistent with the overall statutory scheme. First, the government’s reading found support in section 2302(a)(2), the provision immediately following the one at issue. Second, topping off SNAP benefits at the maximum monthly allotment for all participants was consistent with the statute governing USDA’s response to other crises. Third, if Congress wished to provide across-the-board relief to households based on increased food costs, it would have most naturally modified the metric designed to measure 4 HALL V. USDA those costs – the thrifty food plan. See 7 U.S.C. §§ 2012(u), 2017(a). The panel concluded that because plaintiffs were unlikely to succeed on the merits of their claims, the district court did not abuse its discretion in denying a preliminary injunction. Chief Judge Thomas dissented because he would hold that plaintiffs established a clear likelihood of success on their claims that the agency’s interpretation of section 2302(a)(1) of the Families First Act could not stand under 5 U.S.C. § 706(2). The plain language of section 2302(a)(1) compelled the conclusion that Congress did not intend to limit the emergency assistance available under that provision to the maximum amount that SNAP households may receive under non-emergency conditions. Chief Judge Thomas would reverse the denial of the preliminary injunction and remand to the district court for consideration of the remaining factors under Winter v. NRDC, Inc., 555 U.S. 7, 20 (2008).
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