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Bread for the City v. United States Department of Agriculture
2017 U.S. App. LEXIS 19525
| D.C. Cir. | 2017
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Background

  • 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.

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Case Details

Case Name: Bread for the City v. United States Department of Agriculture
Court Name: Court of Appeals for the D.C. Circuit
Date Published: Oct 6, 2017
Citation: 2017 U.S. App. LEXIS 19525
Docket Number: 16-5329
Court Abbreviation: D.C. Cir.