Euclid Market Inc. v. United States, No. 22-1301 (8th Cir. 2023)
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The United States Department of Agriculture (“USDA”) permanently disqualified Euclid Market Inc. (“Euclid Market”) from the Supplemental Nutrition Assistance Program (“SNAP”) after it determined Euclid Market had unlawfully trafficked SNAP benefits. After the USDA issued its final decision, Euclid Market filed an action in federal court under 7 U.S.C. Section 2023, requesting the district court set aside the USDA’s final decision. The district court found Euclid Market did not meet its burden to show the USDA’s action was invalid and entered judgment in favor of the government. Euclid Market appealed. Euclid Market argued that the district court erred by requiring it to produce transaction-specific evidence for every transaction raised by the USDA to meet its burden of proof.
The Eighth Circuit vacated the judgment and remanded. The court agreed with Euclid Market that the transaction-specific standard is erroneous and that the district court applied such a standard in this case. A store’s failure to provide transaction-specific evidence for every transaction does not inherently doom its case. Concluding otherwise would create unnecessary tension with the fundamental principles of evidence. Further, a hardline rule that a store cannot prevail without transaction-specific evidence for each transaction raised by the USDA is inconsistent with the district court’s rightful discretion in weighing all of the relevant, admissible evidence to determine the validity of the disqualification by a preponderance of the evidence.
Court Description: [Grasz, Author, with Shepherd and Kelly, Circuit Judges] Civil case - Supplemental Nutrition Assistance Program. Plaintiff was disqualified from participation in SNAP after the USDA determined that it had unlawfully trafficked in SNAP benefits. Plaintiff sued under the provisions of 7 U.S.C. Sec. 2023, and the district court found plaintiff had not met its burden to show the USDA's action was invalid. Plaintiff appeals. The district court did not err in placing the burden of proof on plaintiff; however, the district court erred by requiring plaintiff to produce transaction-specific evidence for every transaction raised by the USDA in order to meet its burden of proof; plaintiff may satisfy its burden of proof with evidence that serves to reduce the suspicion associated with a certain pattern of transactions the USDA identified; remanded to the district court for further proceedings. Judge Shepherd, dissenting.
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