467 F.Supp.3d 838
N.D. Cal.2020Background
- COVID-19 prompted Congress to enact the FFCRA, which in Section 2302 authorizes USDA to provide, at a State's request, "emergency allotments" under SNAP "to address temporary food needs not greater than the applicable maximum monthly allotment for the household size."
- USDA issued guidance interpreting that statutory cap to mean a household’s total monthly SNAP benefit (regular + emergency) cannot exceed the statutory maximum, so households already receiving the maximum regular allotment are ineligible for emergency allotments.
- California’s CDSS initially proposed broader supplements (a $60 per person allotment irrespective of whether households already received the maximum); USDA rejected that plan and instead approved California’s revised request that raised households only up to the statutory maximum.
- Two California SNAP recipients who already receive the maximum benefits sued under the APA, seeking a class and a preliminary injunction compelling USDA to approve emergency allotments even for households already at the statutory maximum.
- The district court treated the requested relief as a mandatory injunction, applied the heightened Winter/Stanley standard, and denied the preliminary injunction on grounds that plaintiffs did not show a clear likelihood of success on the merits and raised redressability concerns.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper reading of "not greater than the applicable maximum monthly allotment" in §2302(a)(1) | Phrase modifies only the emergency allotment amount; emergency allotments may be paid even to households already receiving the statutory maximum | Phrase caps the aggregate monthly benefit (regular + emergency); households already at maximum cannot receive additional emergency allotments | Court: Statute ambiguous; USDA’s aggregate-cap reading is a reasonable interpretation; plaintiffs failed to show a clear likelihood of success |
| Type of injunction sought | Plaintiffs framed relief as prohibitory but substantively seek an order compelling USDA to approve certain requests | USDA says relief is mandatory (would alter status quo) | Court: Relief is a mandatory injunction, triggering a heavy burden for plaintiffs |
| Irreparable harm and public-interest balance | Emergency need for food assistance to vulnerable households during pandemic | USDA stresses statutory limits and appropriations concerns; Congress controls funding choices | Court: Declined to find the requisite showing because plaintiffs failed on likelihood of success; equities/public interest do not overcome that failure |
| Redressability | If court compels USDA interpretation, California will request and provide emergency allotments to class members | USDA notes states (sovereigns) must request and elect to distribute; plaintiffs cannot force state action | Court: Redressability speculative because California is not a party and may exercise independent discretion; weighs against injunction |
Key Cases Cited
- Winter v. Natural Resources Defense Council, 555 U.S. 7 (2008) (standard for preliminary injunctions requiring likelihood of success, irreparable harm, balance of equities, and public interest)
- Alliance for the Wild Rockies v. Cottrell, 632 F.3d 1127 (9th Cir. 2011) (serious questions/balance of hardships alternative standard for injunctions)
- Marlyn Nutraceuticals, Inc. v. Mucos Pharma GmbH & Co., 571 F.3d 873 (9th Cir. 2009) (mandatory injunctions are disfavored and require heightened justification)
- Stanley v. University of Southern California, 13 F.3d 1313 (9th Cir. 1994) (mandatory injunctions require a clear likelihood of success on the merits)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing and redressability requirements)
- ASARCO, LLC v. Celanese Chem. Co., 792 F.3d 1203 (9th Cir. 2015) (statutory interpretation: enforce plain language in context)
- Carson Harbor Village, Ltd. v. Unocal Corp., 270 F.3d 863 (9th Cir. 2001) (statutes must be read in their broader statutory and regulatory context)
- Glanton ex rel. ALCOA Prescription Drug Plan v. AdvancePCS Inc., 465 F.3d 1123 (9th Cir. 2006) (no redressability when relief depends on independent actor's discretionary choice)
- Garcia v. Google, Inc., 786 F.3d 733 (9th Cir. 2015) (mandatory injunctions alter the status quo and are therefore disfavored)