If allowed to stand, the rule would have left “states scrambling and exponentially [increased] food insecurity for tens of thousands of Americans” by significantly restricting the threshold for when they could waive work requirements for recipients of the Supplemental Nutrition Assistance Program, wrote US District Court Chief Judge Beryl Howell.
In particular, Howell estimated 700,000 able-bodied 18- to 49-year-olds without children likely would have been kicked out of the program unless they could work at least 20 hours a week for more than three months over a 36-month period. While states currently can waive this requirement in areas struggling with unemployment, the new rule would have limited those waivers to areas with 6% unemployment or higher in an effort to save $5.5 billion over five years.
Given the ongoing coronavirus pandemic has caused SNAP rosters to grow by more than 17% with more than 6 million new enrollees since May 2020, Howell criticized USDA for being “icily silent” about how many more people “would have been denied SNAP benefits had the changes sought in the Final Rule been in effect while the pandemic rapidly spread across the country.”
In an earlier ruling, Howell temporarily blocked the rule on March 13 when President Trump declared a national emergency due to the coronavirus pandemic. The requirement also was temporarily waived by Congress as part of emergency legislation but would have gone into effect eventually without Howell’s decision on Oct. 18.
In her current ruling, Howell blocked the rule because she found that USDA failed to provide sufficient notice of changes adopted in the Final Rule, which she said reasonable parties would not have anticipated, and which were “arbitrary and capricious and not in accordance with the law.”
She also argued the rule’s discretionary exemption change is contrary to law, and that it ignored evidence of negative financial impact on state governments and protected groups.
Finally, she criticized USDA for dismissing the rule’s impact on “vulnerable populations, including racial and ethnic minorities, LGBTQ populations, veterans, homeless populations and those with disabilities” on the grounds that it did not have sufficient data about the impact on these groups.
“That excuse rings hollow given the many comments supported by ‘empirical data,’” submitted to the agency during the rule review period, she wrote.
‘A win for common sense and basic human decency’
Responding to this weekend’s decision, several of the attorneys general and other stakeholders of the 19 states, DC, New York City and private groups that brought the case against USDA lauded the ruling as fair.
New York Attorney General Letitia James said the decision was “a win for common sense and basic human decency.”
Echoing these sentiments, Lauren Bauer, fellow at The Hamilton Project at the Brookings Institute said in a statement that Howell’s decision to overturn the Trump administrations “draconian SNAP work requirements rule” will provide much-needed relief to many Americans suffering during the pandemic.
“At a time when one in three US households with children is food insecure, and food banks throughout the nation continue to experience unprecedented demand, the idea of our federal government adding any additional barriers to receiving SNAP benefits is unconscionable,” she said.
“Instead of kicking our fellow Americans while they are already down, this ruling, in conjunction with the nationwide SNAP work requirement suspension, will help millions of Americans who are down on their luck purchase groceries,” she added.
