A federal judge in Rhode Island granted an emergency temporary restraining order on October 31, blocking the Trump administration’s suspension of Supplemental Nutrition Assistance Program (SNAP) benefits and ordering the immediate release of federal funds to continue food assistance for millions nationwide.

U.S. District Judge John J. McConnell Jr. ruled that the administration’s suspension of SNAP benefits violates the Administrative Procedure Act and would cause irreparable harm to vulnerable populations, nonprofits, food retailers, and local governments struggling to respond to the crisis.

On October 10, 2025, the U.S. Department of Agriculture (USDA) issued guidance directing all state SNAP agencies to delay transmitting November benefit issuance files to electronic benefit transfer (EBT) vendors, citing insufficient funds due to the government shutdown. On October 24, USDA escalated its action, formally suspending all November 2025 benefit allotments, directing states to take immediate action to implement the suspension, and notifying SNAP recipients that they would not receive benefits beginning November 1.

The suspension would be the first time benefits would be cut off due to a government shutdown, despite Congress appropriating contingency funds specifically designated for such circumstances.

A coalition of Rhode Island organizations, unions, nonprofits, cities, and businesses filed suit in U.S. District Court for the District of Rhode Island, arguing that USDA’s actions violated federal law. The plaintiffs included:

Direct SNAP Recipients and Community Representatives: The Service Employees International Union (SEIU), whose members include SNAP recipients facing imminent loss of food assistance; workers earning low wages who depend on SNAP to supplement inadequate incomes.​

Cities and Municipalities: The Cities of Providence, Central Falls, Pawtucket, and New Haven, which would be forced to divert critical municipal resources and emergency services to address food insecurity, homelessness, and related social crises.​

Faith-Based Organizations and Nonprofits: The Rhode Island State Council of Churches, the National Council of Nonprofits, United Way of Rhode Island, Federal Hill House, and The Milagros Project—organizations already strained by increased demand at their food pantries and facing overwhelming calls for emergency assistance.​

Food Retailers: Black Sheep Market and other small businesses dependent on SNAP transactions for substantial revenue, representing businesses in food deserts serving low-income communities.​

Plaintiffs argued that USDA’s suspension violated the Administrative Procedure Act on multiple grounds:

Contrary to Law: Congress established SNAP as a mandatory entitlement program, requiring that “assistance under this program shall be furnished to all eligible households.” The statute leaves no room for discretion when appropriated funds are available. Plaintiffs documented that Congress had appropriated $6 billion in contingency reserve funds through fiscal years 2024 and 2025, explicitly designated for use “when necessary to carry out program operations.” Additionally, USDA possessed authority under 7 U.S.C. § 2257 to access approximately $23 billion in Section 32 funds, which the agency was already using to fund the Women, Infants & Children (WIC) program during the same shutdown.​

Arbitrary and Capricious: USDA failed to provide a reasoned explanation for refusing to access available contingency funds, despite having done so under previous administrations, including during the first Trump administration in 2019. The agency ignored the massive harms to SNAP recipients, nonprofits, food retailers, and municipalities. The USDA posted a banner on its website blaming Senate Democrats for the situation and claiming “there will be no benefits issued November 01,” suggesting the decision was driven by political motives rather than legal necessity.

Unlawfully Withheld Agency Action: USDA refused to take discrete steps mandated by law—specifically, releasing available contingency funds and other appropriations necessary to furnish SNAP assistance to eligible households.​

Early Termination of Work Requirement Waivers: In addition to suspending benefits, USDA prematurely terminated waivers for able-bodied adults without dependents (ABAWDs) with insufficient job opportunities. These waivers had been approved through February 28, 2026, but were terminated effective November 2 without legal authority or warning, with no statutory provision authorizing USDA to terminate previously approved waivers.

After an hour-long emergency hearing on October 31, Judge McConnell found that plaintiffs had established all four prerequisites for emergency relief under the Administrative Procedure Act. The judge granted the temporary restraining order, ordering USDA to “distribute the contingency money timely, or as soon as possible, for the November 1 payments to be made” and to notify the court by Monday how SNAP would be funded going forward.

The court found that plaintiffs were likely to succeed on their claims that USDA acted without lawful authority and that the suspension violated the Administrative Procedure Act’s prohibition on arbitrary and capricious agency action.

The temporary restraining order remains in effect pending the preliminary injunction hearing, during which the court will determine whether the order should remain in place for the duration of the litigation.