UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
COMMONWEALTH OF MASSACHUSETTS ET AL.,
Plaintiffs,
V.
UNITED STATES DEPARTMENT OF AGRICULTURE ET AL.,
Defendants.
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Civil Action No. 1:25-cv-13165-IT
MEMORANDUM AND ORDER
October 31, 2025
TALWANI, D.J.
Pending before the court is Plaintiffs' Motion for a Temporary Restraining Order [Doc.
No. 3] seeking to enjoin, on an emergency basis, Defendants' November 1, 2025 suspension of benefits under the Supplemental Nutrition Assistance Program ("SNAP"). For the reasons stated
below, Plaintiffs have standing to bring this action and are likely to succeed on their claim that
Defendants' suspension of SNAP benefits is unlawful. Where that suspension of benefits rested
on an erroneous construction of the relevant statutory provisions, the court will allow Defendants
to consider whether they will authorize at least reduced SNAP benefits for November, and report
back to the court no later than Monday, November 3, 2025.
A. Likelihood of Success on the Merits
Plaintiffs have demonstrated a strong likelihood of success on the merits of their claim under the Administrative Procedure Act, 5 U.S.C. § 706(2)(A), (C), that Defendants' suspension of SNAP benefits is contrary to law. At core, Defendants' conclusion that USDA is statutorily prohibited from funding SNAP because Congress has not enacted new appropriations for the
current fiscal year is erroneous. To the contrary, Defendants are statutorily mandated to use the
previously appropriated SNAP contingency reserve when necessary and also have discretion to
use other previously appropriated funds as detailed below.
As both parties acknowledge, Congress has not yet appropriated any new funds for SNAP
benefits for Fiscal Year 2026, which began on October 1, 2025. Pls.' Mem. 6 [Doc. No. 4];
Defs.' Opp'n 7 [Doc. No. 18]. But Congress took steps to protect against the deprivation of
SNAP assistance. In the 2024 Consolidated Appropriations Act, Pub. L. No. 118-42, § 6, 138
Stat. 25, 93-94, Congress separately appropriated $6 billion to the SNAP program "to remain available through September 30, 2026" and "be placed in reserve for use only in such amounts and at such times as may become necessary to carry out program operations." See also Pub. L.
No. 119-4, § 1101(a), 139 Stat. 9, 10 (2025). As Plaintiffs point out, given the mandatory nature
of SNAP benefits under 7 U.S.C. § 2014(a) and the appropriation of these funds to be available
10
Case 1:25-cv-13165-IT
Document 26 Filed 10/31/25
Page 11 of 15
through this current fiscal year, the government is obligated to use this contingent reserve
account to fund SNAP "as may become necessary to carry out program operations." 138 Stat. at
93-94; Pls.' Mem. 11 [Doc. No. 4].
Defendants argue out that a "suspension" is permitted under USDA's regulations, and that USDA "has consistently interpreted its authority to allow for the suspension or cancellation of benefits when necessary." Defs. Opp'n 6 [Doc. No. 18). The regulation at issue, 7 C.F.R. $ 271.7(a), sets forth procedures to be followed if monthly SNAP allowances "must be reduced, suspended, or cancelled to comply with section 18 of the Food and Nutrition Act of 2008"
(emphasis added). But that the regulation allows for a suspension when there are no funds does
not mean that Defendants may choose a suspension over a reduction while funds do remain. If
the regulation did authorize such discretion, it would be inconsistent with the statutory mandate that benefits "shall" be paid unless funding is no longer available.
BREAKING: Federal judge rules that the Trump administration likely illegally suspended SNAP benefits, ruling that at least reduced distribution is required to go forward under law using the $6 billion reserve fund.
Judge gives the Trump admin until Monday to respond as to whether it will act.
31.10.2025 17:59 — 👍 2697 🔁 1040 💬 22 📌 103
Whenever people complain about the number of folks relying on food stamps, it is worth reminding them that SNAP is, by too large of a degree, a subsidy for corporations that refuse to pay a living wage and their political allies who reject public policy prescriptions to reduce income inequality.
27.10.2025 01:11 — 👍 34665 🔁 11441 💬 866 📌 683
We’re putting food on the table in Argentina ($40 billion), yet MAGA Republicans are threatening to withhold SNAP funds already allocated by Congress. MAGA = Make Argentina Great Again.
26.10.2025 18:14 — 👍 3318 🔁 1024 💬 119 📌 22
Wah wah wah goes the cry baby
26.10.2025 01:16 — 👍 0 🔁 0 💬 0 📌 0
World Series, Stadium Edition: Rogers Centre vs. Dodger Stadium 🤔
24.10.2025 18:59 — 👍 152 🔁 30 💬 19 📌 35
I'm not sure you can get more marie antoinette than taking away food stamps before thanksgiving while you build a gold and marble dance hall so the other crooks can bring bribe you over a badly-cooked (argentinian) steak
22.10.2025 11:53 — 👍 17495 🔁 5781 💬 367 📌 239
My favourite player with my kids’ favourite player.
21.10.2025 03:22 — 👍 304 🔁 19 💬 4 📌 0
remote work is like birth control or UBI atp where there’s overwhelming research consensus they improve quality of life for people they apply to, yet access is impeded or blocked by the ruling class because the thought of marginalized ppl having rich full lives makes steam come out their ears
16.10.2025 17:28 — 👍 3638 🔁 1265 💬 39 📌 32
Every year, millions of low-income Canadians miss out on benefits they’re entitled to.
We’re stepping in — with new Automatic Federal Benefits. Canada’s new government will pre-file taxes for up to 5.5 million Canadians, getting them back money that would otherwise go unclaimed.
15.10.2025 16:56 — 👍 774 🔁 152 💬 36 📌 20
Having to upload a resume and then monotonously input every detail into a shitty interface continues to be one of the dumbest things about applying for jobs.
15.10.2025 00:11 — 👍 0 🔁 0 💬 0 📌 0
if you already didn’t have enough reasons to cancel spotify:
14.10.2025 04:24 — 👍 4633 🔁 1581 💬 113 📌 31
The people behind the inflated protests are performing a monumental service to democracy & peace in the US. The Regime wants riots, but these animal characters are not only an effective protest, grabbing attention & mocking ICE, they seem to reduce the risk of violent protests. It's perfect.
14.10.2025 10:21 — 👍 1411 🔁 316 💬 21 📌 17
Sometimes I think about how absolutely wild it is that drivers think they're being oppressed when they get punished for breaking the law
12.10.2025 23:45 — 👍 203 🔁 23 💬 7 📌 3
Every single one of them is corrupt and taking dark money.
The only thing they're draining from the swamp is money directly to their pockets.
10.10.2025 17:36 — 👍 0 🔁 0 💬 0 📌 0
Solar and batteries had a record-setting, grid-stabilizing summer in…
Solar has set 17 power generation records in Texas so far this year, shoring up the grid alongside batteries as some gas plant developers step back.
The historically volatile Texas grid was entirely stable this summer, despite extreme temperatures. Grid operators never once had to ask Texans to conserve energy or shut off their air conditioners.
Why? Solar & batteries. Want a stable grid? Try solar & batteries.
08.10.2025 18:46 — 👍 1421 🔁 454 💬 20 📌 24
Gonna be thinking about this lede for a minute.
07.10.2025 23:44 — 👍 10763 🔁 4895 💬 190 📌 330
Today is a day when arts degrees are worthless, but the product of those degrees is so valuable it would kill an entire industry if they were made to pay for it.
08.10.2025 10:29 — 👍 26624 🔁 10118 💬 426 📌 185
The Venn diagram of urban density and average household GHG emissions is pretty much a circle. Interesting study on “Mapping household GHG emissions in the Greater Golden Horseshoe” from the University of Toronto School of Cities schoolofcities.utoronto.ca/mapping-hous...
06.10.2025 11:09 — 👍 226 🔁 80 💬 5 📌 21
“Terrible things are happening outside. Poor helpless people are being dragged out of their homes. Families are torn apart. Men, women, and children are separated. Children come home from school to find that their parents have disappeared.”
Diary of Anne Frank
January 13, 1943
04.10.2025 20:17 — 👍 17144 🔁 8044 💬 259 📌 339
Zohran Mamdani tells CNN:
"If Netanyahu comes to deliver a speech at the United Nations General Assembly in New York next year while I am mayor, I will move to honour the ICC arrest warrant issued in The Hague against him, just as I would against Putin. He is responsible for the genocide in Gaza.”
02.10.2025 19:37 — 👍 3140 🔁 696 💬 68 📌 71
Jones, 27, is among the residents left at 7500 S. South Shore Drive who are trying to piece together what remains after an early morning, high-powered federal immigration raid led to the arrests of dozens of their neighbors at their South Shore apartment building.
Armed federal agents in military fatigues busted down their doors overnight, pulling men, women and children from their apartments, some of them naked, residents and witnesses said. Agents approached or entered nearly every apartment in the five-story building, and U.S. citizens were among those detained for hours.
When he got home from work, Jones said he entered his unit to find all of his electronics and furniture missing, and all of his clothes and shoes thrown on the floor. Jones said he had no idea who took his belongings and hadn’t received answers from Chicago police.
“I’m pissed off,” Jones said. “I feel defeated because the authorities aren’t doing anything.”
On Wednesday, toys, shoes and food were still in piles in the building’s hallways. Property managers were seen throwing mattresses and broken doors into dumpsters.
"Armed federal agents in military fatigues busted down their doors overnight, pulling men, women and children from their apartments, some of them naked, residents and witnesses said."
www.wbez.org/immigration/...
02.10.2025 23:53 — 👍 1443 🔁 704 💬 76 📌 52
This is so indefensibly insane: Speaker Johnson is refusing to seat Congresswoman-elect Adelita Grijalva because she'll be the 218th vote to release the Epstein files. Johnson swore in Rep Walkinshaw (VA) w/in 24 hours.
Johnson is abandoning his job to instead protect a convicted child sex predator
02.10.2025 14:23 — 👍 12459 🔁 4829 💬 757 📌 336
Black folk will tell you: The 1st thing cops say after an incident is always a lie.🤷🏿♂️
They lie because there's upside in it for them, and no downside.
No matter how many times they get caught lying, newspapers will print their next lie as the gospel truth.🤡
And people stop caring before truth hits
02.10.2025 02:09 — 👍 1704 🔁 641 💬 13 📌 5
Jane Goodall, ethologist and conservationist, has died. She was 91
01.10.2025 18:02 — 👍 28513 🔁 7691 💬 1262 📌 1958
Republicans are more worried about blaming Dems than actually having any conversation. We knew this would happen, I just pray that people don't fall for it.
When it shut down under the Dems because of blatant obstruction of Republicans the population blamed the Dems.
Better blame the right idiots.
01.10.2025 17:46 — 👍 1 🔁 1 💬 0 📌 0
Much like the bike lane ban, it's a distraction I'm sure, but what insane corrupt thing is coming to light now??
Also why does Ford absolutely want to see people killed by cars? I don't understand why he is demanding human sacrifice to drivers.
25.09.2025 17:29 — 👍 1 🔁 0 💬 0 📌 0
Kitty figurines for Halloween
Hey there! I have mews!
- shipping to the USA is back
- next restocks : oct 5th + oct tbd
- customs are being fulfilled, next batch : mid October.
Also thanks for your support and patience it means a lot !
24.09.2025 23:57 — 👍 177 🔁 26 💬 0 📌 0
Kenya transgender rights victory hailed as African first
QNews LGBTIQA+ News
it's so nice to see what a functioning judiciary looks like
"A transgender woman in the East African nation of Kenya has won a landmark court victory in which the judge not only found in her favour, but ordered the government to pass a Transgender Protection Rights Act."
fuck yeah
23.09.2025 15:35 — 👍 14775 🔁 4336 💬 26 📌 159
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