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![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.](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:36eqtmzysqf7wsslczw4uxcd/bafkreiczapq36myqhzcrdp4jfodg5rkso7nuvlta4e5b5r4l5upce7b3le)
![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
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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].](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:36eqtmzysqf7wsslczw4uxcd/bafkreiac7aa6icx44x5xjkilpwj7il5oriyttttnrslzrhkwvw6b32cbnm)
