Judge Blocks Trump SNAP Penalty Countdown Over Missing Federal Guidance
A federal judge blocked the 120-day SNAP penalty countdown due to missing guidance to states.
Why it matters: This decision protects states from penalties imposed without clear federal instructions, impacting welfare enforcement policies and administrative law compliance strategies for legal teams.
- U.S. District Judge Mustafa Kasubhai ruled on September 17, 2026, that starting the SNAP penalty countdown before issuing state guidance was unlawful.
- The ruling enforces a permanent injunction, originally a December 2025 preliminary injunction, barring penalties on states missing the deadline.
- The Trump administration’s SNAP rule changes excluded some lawful permanent residents eligible for aid, sparking legal challenges.
- A coalition of 22 states plus D.C., led by Oregon and New York, sued to block the policy and enforcement approach.
On September 17, 2026, U.S. District Judge Mustafa Kasubhai ruled that the Trump administration unlawfully started the 120-day countdown to penalize states under new Supplemental Nutrition Assistance Program (SNAP) rules before providing required federal guidance.
The court upheld a permanent injunction initially issued as a preliminary measure in December 2025, blocking federal penalties against states that missed compliance deadlines set without sufficient instruction. The judge emphasized the necessity of clear federal direction before enforcing such deadlines, citing administrative fairness.
The controversy arises from SNAP eligibility changes under the Trump administration that excluded specific lawful permanent residents—including some former refugees and asylum seekers who are otherwise eligible—from program access. These exclusions led to lawsuits challenging both the policy and its enforcement timeline.
A coalition of 22 states plus the District of Columbia, with Oregon and New York at the forefront, filed suit against the federal government’s approach. Oregon Attorney General Dan Rayfield, in a state press release, said the administration's enforcement triggered "significant uncertainty and hardship for states administering emergency food programs," highlighting risks of rushed implementation.
This ruling reinforces the critical role of federal-state collaboration and clear procedural guidance in administering welfare programs. Legal teams should note this precedent for challenges to agency deadlines imposed without proper notice or support.
By the numbers:
- 22 states plus the District of Columbia — plaintiff coalition against the SNAP rules
- 120 days — countdown period to penalty enforcement blocked by the court
- December 2025 — date when the initial preliminary injunction was granted