AJ Mini Market, Inc. v. United States, 73 F.4th 1

AJ Mini Market, a Woonsocket convenience store authorized for SNAP since 1989, was investigated after FNS data flagged unusual spending (Dec 2018–May 2019).
FNS charged the Market with 384 violations (high-value transactions, rapid successive purchases, and rapid depletion of household SNAP benefits) and proposed permanent disqualification.
The Market submitted 174 pages of receipts and argued customers shop in bulk; it did not identify customers or provide compliance/training documentation.
FNS permanently disqualified the Market; a review officer upheld the finding and sanction; the Market sued in district court challenging liability and the sanction.
The district court granted summary judgment for the United States; the First Circuit affirmed, holding circumstantial evidence supported an inference of trafficking and the Market failed to rebut it, and that the permanent disqualification was not arbitrary or capricious.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Market trafficked in SNAP benefits based on circumstantial data	Transactions were legitimate retail sales; data alone is insufficient	FNS's data and store observations created a strong inference of trafficking	Court: Circumstantial evidence adequate; Market failed to rebut; liability upheld
Whether submitted receipts and explanations rebut the trafficking inference	Receipts show legitimate purchases (bulk shopping, baby formula)	Receipts are vague ("DELI", "MISC"), don't identify households, and raise further questions	Court: Receipts insufficient to overcome FNS's inference
Whether permanent disqualification was an appropriate sanction (vs monetary penalty)	Monetary penalty would be sufficient; permanent ban is unduly harsh	FNS has discretion; store failed to meet regulatory criteria for reduced penalty	Court: Sanction not arbitrary or capricious; Market failed to prove entitlement to monetary penalty
Whether community hardship should affect sanction	Disqualification will harm local low-income shoppers	Hardship is not a factor for permanent disqualification and alternatives exist nearby	Court: Community hardship not a valid basis to overturn permanent disqualification

Minturn v. Monrad, 64 F.4th 9 (1st Cir. 2023) (summary-judgment standard and appellate review)
Irobe v. U.S. Dep't of Agric., 890 F.3d 371 (1st Cir. 2018) (circumstantial evidence can support trafficking finding; store bears burden to rebut)
Idias v. United States, 359 F.3d 695 (4th Cir. 2004) (examples of trafficking via cash-for-benefits and rapid successive transactions)
Euclid Mkt. Inc. v. United States, 60 F.4th 423 (8th Cir. 2023) (large transactions relative to store inventory as trafficking indicator)
Fells v. United States, 627 F.3d 1250 (7th Cir. 2010) (comparative-transaction analysis with nearby stores supports inference)
DePoutot v. Raffaelly, 424 F.3d 112 (1st Cir. 2005) (conclusory allegations and speculation insufficient to defeat summary judgment)
Teamsters Local No. 59 v. Superline Transp. Co., 953 F.2d 17 (1st Cir. 1992) (waiver of arguments not raised below)
Mass. Dep't of Pub. Welfare v. Sec'y of Agric., 984 F.2d 514 (1st Cir. 1993) (standard for overturning agency sanction)
7-Eleven #22360 v. United States, 560 F. Supp. 3d 892 (D. Md. 2021) (distinguishable: limited incidents and extensive compliance documentation)
Ahmed v. United States, 47 F. Supp. 2d 389 (W.D.N.Y. 1999) (discussion of "unduly harsh" sanction in context of preliminary relief)