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Dec 16, 2025

Judge Extends Compliance Deadline for States on SNAP Immigration Restrictions

Judge Extends Compliance Deadline for States on SNAP Immigration Restrictions
A federal court in Oregon on December 15 granted 22 jurisdictions—21 states and the District of Columbia—an injunction that pushes the deadline for implementing new immigration-related limits on Supplemental Nutrition Assistance Program (SNAP) benefits from November 1 to April 9. U.S. District Judge Mustafa Kasubhai ruled that the U.S. Department of Agriculture’s (USDA) guidance could improperly exclude certain lawful permanent residents, asylees and refugees from food assistance, and that states faced potential financial penalties if forced to enforce the rules prematurely.

The underlying restrictions stem from a 2020 law signed during President Trump’s first term, but USDA only published detailed compliance instructions this summer. Plaintiffs argued the agency failed to follow administrative-procedure norms and offered states contradictory explanations about who would remain eligible. The preliminary injunction preserves the status quo while the lawsuit proceeds on the merits.

Although SNAP lies outside typical corporate-mobility concerns, the decision highlights a broader trend: benefit programs increasingly tie eligibility to immigration status, creating indirect pressure on employers sponsoring assignees and their families. Relocation managers working with foreign nationals who convert to permanent residence should monitor how state agencies interpret “qualified alien” status when delivering ancillary benefits such as childcare subsidies or Medicaid.

Judge Extends Compliance Deadline for States on SNAP Immigration Restrictions


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From a policy standpoint, the ruling underscores the judiciary’s willingness to scrutinize agency interpretations that narrow statutory rights for immigrants, suggesting similar challenges could emerge against forthcoming DHS fee increases or USCIS document-validity changes. Multistate employers must therefore track a patchwork of timelines and court orders that affect workers’ access to public resources, which in turn influence cost-of-living packages and hardship allowances.

Next steps: USDA is expected to appeal to the Ninth Circuit but may also issue revised guidance. Employers should flag the April 9 deadline in case budgeting for state-level benefits becomes necessary.
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