A diverse group—including churches, municipalities, nonprofits, a labor union, and even a grocery store—has taken legal action against the Trump administration in Rhode Island. Their lawsuit challenges the suspension of Supplemental Nutrition Assistance Program (SNAP) benefits.

On October 10, a memo from the acting associate SNAP administrator was sent to regional and state directors, highlighting a looming crisis. The memo warned that if the current funding lapse persisted, there wouldn’t be enough money to fully cover November SNAP benefits for about 42 million individuals nationwide.

The memo further explained that SNAP offices would typically start issuing November benefits to the vendors responsible for electronic benefit transfer (EBT) cards and related payments “soon.” However, due to various complications, states were instructed to withhold their November issuance files and delay sending them to state EBT vendors until further instructions were provided.

By October 24, the situation had escalated. A follow-up memo from the U.S. Department of Agriculture (USDA) announced the suspension of all November 2025 benefits until federal funding was secured or until the USDA’s Food and Nutrition Service advised state agencies to proceed differently.

Interestingly, the lawsuit isn’t based solely on the absence of SNAP funds. Instead, the plaintiffs argue that funds actually exist, questioning the reasons behind the suspension.

On the same day, a related memo from the USDA informed SNAP administrators that contingency funds were unavailable for supporting the fiscal year 2026’s regular benefits, as the appropriation for these benefits had been eliminated.

The government’s claim about the availability of SNAP contingency funds was made “without any citation or legal support,” according to the plaintiffs’ 40-page complaint filed Thursday.

The lawsuit cites appropriations provisions from the current and past year to support their claim SNAP contingency funds are available.

From the filing, at length:

In the Consolidated Appropriations Act of 2024, Congress appropriated more than $122 billion for SNAP. Of that sum, Congress directed that $3 billion, “to remain available through September 30, 2026, shall be placed in reserve for use only in such amounts and at such times as may become necessary to carry out program operations.”

Congress maintained those funding levels for the SNAP program in the Full-Year Continuing Appropriations and Extensions Act of 2025, meaning that an additional $3 billion was put aside in a reserve available through September 30, 2027.

In other words, the plaintiffs say last year’s government funding bill — which was passed in March 2024 — explicitly accounted for SNAP contingency funds to keep the program afloat for nearly 2 1/2 years. Then, the plaintiffs say, Congress essentially maintained that language for SNAP in this year’s short-term government funding bill.

In fact, the plaintiffs say, there’s even more money the government could draw from in order to continue funding SNAP benefits.

“Aside from the contingency funds, USDA is authorized under 7 U.S.C. § 2257 to use a percentage of appropriated funds ‘interchangeably’ for certain expenditures,” the lawsuit goes on. “One appropriated fund available to USDA—a fund created by section 32 of the Agricultural Adjustment Act amendments of 1935—had over $23 billion in it as of October 8, 2025.”

The lawsuit also says the federal government itself has previously understood SNAP contingency funds to be available in the case of a shutdown — including a previous iteration of Trump’s own government.

“Previous administrations issued guidance indicating that these contingency funds are available if SNAP funds lapse due to a government shutdown,” the lawsuit goes on. “During the first Trump administration, USDA advised regional partners that funding from the contingency reserve was available to provide SNAP benefits. Similarly, during the Obama administration, USDA guidance indicated that contingency funds could be used for SNAP benefits.”

The plaintiffs, led by the Rhode Island State Council of Churches, an ecumenical group of churches throughout the Ocean State, say the new interpretation of law advanced by the second Trump administration has “needlessly plunged SNAP into crisis.”

“[T]here are appropriated funds available that could—and must—be used for those benefits,” the lawsuit goes on. “USDA’s suspension of SNAP benefits is contrary to law and arbitrary and capricious, and its failure to fund SNAP constitutes agency action unlawfully withheld.”

The lawsuit is largely premised on violations of the Administrative Procedure Act (APA), the federal statute governing the action of administrative agencies. Chiefly, the plaintiffs say the cessation of SNAP benefits violates the aforementioned arbitrary and capricious standard, a term of art which refers to government actions that go too far while simultaneously eschewing formal, mandatory processes.

“USDA failed to provide a reasoned explanation for its decision not to fund the SNAP program with available appropriations,” the complaint continues. “USDA also failed to acknowledge that its decision not to use contingency funding reflects a change in policy or to reasonably explain the reasons for that change.”

The government’s lack of explanation and finality of action makes the move to defund SNAP — despite billions of available and appropriated dollars — untenable under the APA, the lawsuit claims.

The thrust of the lawsuit is that the Trump administration’s pleas of poverty with regard to the SNAP program simply are not true.

“Defendants’ withholding of funds is also arbitrary and capricious because its premise that no funds are available is incorrect; in fact, funds are available both from the FY 2024 and FY 2025 contingency appropriations and in the funds available under 7 U.S.C. § 2257,” the filing continues. “The nonfunding of SNAP benefits must be declared unlawful and set aside.”

The lawsuit seeks injunctive relief to stay the directives and keep SNAP benefits in place using the above-mentioned funding sources.

The case has been assigned to U.S. District Judge John James McConnell Jr., a Barack Obama appointee.