Bread for the City v. United States Department of Agriculture
2017 U.S. App. LEXIS 19525
| D.C. Cir. | 2017Background
- Bread for the City sued USDA alleging it underspent the Emergency Food Assistance Program by hundreds of millions relative to 7 U.S.C. § 2036(a) as amended by the Agricultural Act of 2014.
- The Program requires USDA to purchase surplus commodities and distribute them to States, which then supply local nutrition-assistance organizations (treated as States for the Program).
- Section 2036(a)(2) lists dollar amounts: fixed amounts for 2008–2009, an inflation-adjusted base for 2010–2018 (subparagraph (C)), and additional specified sums for 2015–2018 (subparagraph (D)).
- For FY2015 USDA calculated total spending as $327 million (base $250M + inflation adj. $27M + $50M supplement) and spent that amount; Bread for the City argued USDA should have spent $604 million treating (C) and (D) as separate, additive mandates.
- The district court dismissed the complaint for failure to state a claim; the D.C. Circuit affirmed, adopting USDA’s interpretation that (D) supplements the amount computed in (C), not that both (C) and (D) require separate full expenditures.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper reading of 7 U.S.C. § 2036(a)(2) — whether (C) and (D) impose separate, additive spending mandates | (Bread for the City) (C) and (D) are standalone requirements; USDA must spend the (C) amount plus the (D) amount (yielding ~$604M for FY2015) | (USDA) (D) is a specified supplement to the (C) amount; Congress intended the total to be (C) plus the listed supplemental dollar figure (yielding ~$327M for FY2015) | Court: Affirmed USDA’s interpretation — (D) supplements (C); plaintiff’s additive reading is implausible and contrary to textual and contextual evidence. |
Key Cases Cited
- Chickasaw Nation v. United States, 534 U.S. 84 (2001) (convoluted statutory readings that strain logic are disfavored; statutes should be read to avoid implausible results)
Affirmed.
