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2.0

USDA instructs states to verify SNAP applicants' citizenship via SSNs and SAVE database

  1. Original Date Announced

    April 24, 2025

    Acting Deputy Under Secretary for Food, Nutrition, and Consumer Services John Walk issued guidance directing state agencies to verify social security numbers (SSNs) and immigration statuses for SNAP applicants, including by verifying SSNs against the Social Security Administration's Death Master File. The guidance further instructs State agencies to collect immigration documents and use the DHS Systematic Alien Verification for Entitlements (SAVE) system to verify citizenship status.

    The guidance also encourages states to adopt certain additional verification measures, discontinue the use of pre-populated application forms, and use SAVE to continuously verify immigration status "since immigration status can quickly change."

    Trump 2.0 [ID #1880]

    2025.04.24 USDA - Improving Eligibility Verification to Support Program Integrity
  2. Effective Date

    April 24, 2025
  3. Subsequent Trump and Court Action

    October 15, 2025

    2025.10.15 Order Granting Preliminary Injunction - California v. USDA

    U.S. District Judge Maxine M. Chesney issued a preliminary injunction, enjoining USDA from disallowing SNAP funding based on plaintiff states’ failure to comply with demands in formal USDA warning letters to plaintiff states on August 20, 2025. The letters asserted that USDA "will initiate a disallowance of Federal funding" if the plaintiff states did not "transmit SNAP enrollment data" to USDA within 30 days. The court found that the plaintiff states were likely to succeed on the merits of their APA claim that USDA's demand for data and threatened disallowance of funding are contrary to law. California v. USDA, No. 3:25-cv-06310 (N.D. Cal.).

    **Link to case here. See litigation note above**

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  4. Subsequent Trump and Court Action

    February 26, 2026

    2026.02.26 Order - California v. USDA

    Judge Chesney granted in part plaintiff states' motion to enforce or expand the preliminary injunction. USDA had renewed its demand that plaintiff states provide the same, previously requested information from their SNAP records on November 24, 2025, and gave notice on December 23, 2025, that it would withhold SNAP funding from any state failing to comply. Plaintiff states filed their motion to enforce or expand the preliminary injunction on January 9, 2026.

    The court noted that USDA's renewed demand was not encompassed in the October 15, 2025 preliminary order, as the order did not enjoin USDA from requesting SNAP records under all circumstances. However, the preliminary injunction was expanded to bar the renewed demand, as plaintiff states showed a likelihood of success on the merits that USDA’s demand and threatened disallowance of funding are contrary to law. California v. USDA, No. 3:25-cv-06310 (N.D. Cal.).

    **Link to case here. See litigation note above**

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  5. Subsequent Trump and Court Action

    April 24, 2025

    2025.07.28 Complaint - California v. USDA

    Twenty-one states and the District of Columbia filed a lawsuit against the USDA, Secretary of Agriculture Brooke Rollins, and USDA's Office of the Inspector General regarding USDA's demand that the states turn over sensitive information about individuals who have applied for SNAP. The complaint alleges that “USDA’s attempt to collect this information from Plaintiff States flies in the face of privacy and security protections in federal and state law.” In particular, it claims that the administration’s actions violate the Administrative Procedure Act, the Spending Clause of the Constitution, and are ultra vires. California v. USDA, No. 3:25-cv-06310 (N.D. Cal.).

    **Link to case here. Our litigation entries generally report only the initial complaint and any major substantive filings or decisions. For additional information, CourtListener provides access to PACER and all available pleadings. Other sites that track litigation in more detail or organize cases by topic include Civil Rights Clearinghouse, Justice Action Center, National Immigration Litigation Alliance, and Just Security**

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