Irobe v. United States Department of Agriculture, No. 17-1943 (1st Cir. 2018)
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The district court properly placed the burden of proof on a grocery store (Store) in this action brought by Plaintiffs alleging that the Store unlawfully trafficked in Supplemental Nutrition Assistance Program (SNAP) benefits.
The Food and Nutrition Service (FNS), the bureau within the United States Department of Agriculture (USDA) charged with administering the SNAP regime, concluded that the Store had engaged in trafficking and permanently disqualified the Store from SNAP participation. The Store brought an action in Maine’s federal district court challenging the agency’s final decision. The district court granted summary judgment for the USDA. The First Circuit affirmed, holding (1) the burden of proof is imposed on the claimant - here, the Store; and (2) no rational fact-finder could conclude that the Store had demonstrated by a preponderance of the evidence that the finding of trafficking was incorrect.
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