Publication Date: November 3, 2025

The U.S. federal government shutdown, entering its second month, has disrupted essential services, including the Supplemental Nutrition Assistance Program (SNAP), which provides food aid to over 41 million Americans. On October 31, 2025, two federal judges ruled that the Trump administration must use contingency funds to continue SNAP payments, rejecting the U.S. Department of Agriculture’s (USDA) plan to suspend benefits starting November 1 due to funding lapses. This decision averts an immediate crisis for recipients, though full benefits may require additional resources. The rulings stem from lawsuits challenging the administration’s interpretation of available funds, highlighting tensions in managing social programs during fiscal deadlocks.

Facts

• The government shutdown began on October 1, 2025, after Congress failed to pass funding legislation, marking the longest such lapse since 2019.
• SNAP, administered by the USDA in partnership with states, delivers monthly benefits averaging $291 per household via Electronic Benefit Transfer (EBT) cards, fully funded by the federal government at approximately $8.6 billion monthly. States handle eligibility determinations and distribution, sharing administrative costs equally with the USDA.
• On October 25, 2025, the USDA announced it lacked authority to use a $5.25 billion contingency fund for November benefits, citing legal restrictions to emergencies like natural disasters, not shutdowns.
• In a lawsuit filed October 29, 2025, by attorneys general from 22 states, the District of Columbia, and governors of Kansas, Kentucky, and Pennsylvania, plaintiffs argued the USDA must tap contingency funds and a separate $23 billion account to sustain the program.
• A parallel suit by Rhode Island municipalities and nonprofits echoed these claims.
• U.S. District Judge Indira Talwani in Boston ruled the suspension unlawful, ordering the USDA by November 4, 2025, to detail use of contingency funds for at least partial benefits.
• U.S. District Judge John J. McConnell Jr. in Rhode Island issued an oral order requiring immediate distribution of contingency funds and a status report by noon on November 4, 2025, stating, “There is no doubt that the six billion dollars in contingency funds are appropriated funds that are without a doubt necessary to carry out the program’s operation.”
• Historically, SNAP traces to the 1930s Food Stamp Program, evolving into a key anti-poverty tool; during the 2018-2019 shutdown, the USDA used similar funds to advance payments.

Perspectives

• Trump Administration: President Donald Trump stated on social media, “I have instructed our lawyers to ask the Court to clarify how we can legally fund SNAP as soon as possible,” emphasizing compliance if legally feasible while arguing the shutdown, not administration policy, created the crisis.
• Agriculture Secretary Brooke Rollins described claims of available funds as “a lie,” asserting the contingency fund requires underlying appropriations.
• State Attorneys General and Governors (Plaintiffs): California Governor Gavin Newsom praised the rulings as “a major win for all Americans,” affirming the administration’s “legal responsibility to support the SNAP program” and urging release of funds to prevent hunger among vulnerable populations.
• Anti-Hunger Advocacy Groups: The Food Research & Action Center, supporting the lawsuits, highlighted that suspending benefits would cause “irreparable harm” to families, with Executive Director Luis Guardia noting in a statement that “SNAP is a lifeline for millions, and these rulings ensure it remains intact during political impasses.”
• House Republicans: Speaker Mike Johnson, in a Capitol press conference, blamed Democratic obstruction for the shutdown, stating contingency funds are not a sustainable solution and calling for bipartisan negotiations to reopen government fully.
• Democratic Congressional Leaders: Senate Minority Leader Chuck Schumer urged an end to the shutdown, saying in a floor statement that “using emergency funds for SNAP is a necessary step, but it underscores the need for responsible budgeting to protect essential services.”
• Center on Budget and Policy Priorities (Neutral Policy Analysts): The organization noted in a published brief that “access to contingency funds aligns with congressional intent for program continuity,” advocating for reforms to prevent future shutdown disruptions.

Considerations

• Prolonged shutdowns exacerbate food insecurity for low-income households, potentially increasing reliance on local food banks and straining community resources in the short term.
• Political polarization in Congress highlights the need for automatic continuing resolutions to maintain core services like SNAP, as proposed in prior bipartisan bills.
• If only partial benefits are issued, states may face higher administrative burdens to adjust EBT distributions, impacting efficiency and equity across regions.
• Broader economic trends show SNAP boosts local economies by $1.50 per dollar spent; sustaining it could mitigate recession risks tied to shutdowns.
• Compared to the U.S.’s 41 million SNAP participants, Brazil’s Bolsa Familia program supports approximately 45 million beneficiaries, while India’s National Food Security Act covers over 800 million people through subsidized food distribution.
• In developed nations like Canada, food bank assistance reaches about 1 million users annually, and the UK’s food aid via charities like the Trussell Trust provides parcels to around 2.5 million people yearly, illustrating smaller scales relative to population in peer economies.
• SNAP’s total federal funding for fiscal year 2024 reached $122.4 billion, with benefits accounting for $108 billion and the federal share of administrative costs, including personnel for eligibility processing and program oversight, estimated at $7 billion; states match this administrative share, bringing total program administration to approximately $14 billion annually.
• Based on USDA data, 33% of SNAP households have earned income, meaning working members contribute to federal revenues through payroll taxes for Social Security and Medicare; however, with average gross monthly household income at $872 (below federal income tax thresholds for most), the demographic primarily consists of low-income individuals who do not pay federal income taxes, so the government funds SNAP largely from broader tax sources rather than directly recycling participants’ income taxes.

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