Federal Court Blocks USDA Guidance on Non-Citizen SNAP Eligibility
A significant legal victory has been achieved by Michigan and several other states against the USDA’s guidelines on food assistance eligibility for non-citizens. This comes after a federal judge’s ruling that halted the implementation of these controversial guidelines.
The dispute began when the U.S. Department of Agriculture (USDA) issued guidelines following the One Big Beautiful Bill Act. This legislation, endorsed by former President Donald Trump, restricted Supplemental Nutrition Assistance Program (SNAP) benefits for numerous lawfully present non-citizens. The states contended that these guidelines imposed stricter limitations than intended by Congress.
One of the central issues was the USDA’s handling of the 120-day adjustment period. States are granted this period to adapt to new eligibility rules without incurring penalties for incorrect payments. However, the USDA’s October 31, 2025 guidance backdated this period to the bill’s passage, effectively concluding on November 1, just after the guidance was released.
Critics argued that this retroactive setting of the adjustment period contradicted established policy, potentially leading to substantial financial penalties for states. The USDA, in its defense, claimed that its guidance served merely as a quick reference and should not be seen as conflicting with legislative intent. It also maintained that states should proactively comply with the law without awaiting formal guidance.
On September 17, a federal judge ruled in favor of Michigan and 21 other states, annulling the USDA’s guidelines. Judge Mustafa Kasubhai emphasized that the USDA’s actions placed states in an untenable position, with the risk of severe financial consequences for non-compliance.
Michigan Attorney General Dana Nessel expressed her approval of the court’s decision, stating that the ruling thwarted the Trump administration’s efforts to unlawfully limit SNAP benefits. “I am relieved the Court rejected the Trump administration’s transparent attempt to exclude certain residents from SNAP benefits in violation of eligibility criteria set by Congress,” said Nessel.
It is important to note that this court ruling does not alter the eligibility limitations introduced by the One Big Beautiful Bill Act, which continue to restrict food assistance access for most non-permanent residents, including refugees and trafficking victims.
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