EUGENE, OREGON – A federal judge on Monday extended the deadline for states to comply with new federal guidance restricting food assistance eligibility for certain non-U.S. citizens, ruling that conflicting instructions from the Agriculture Department made timely implementation unrealistic. The judge found that states were hindered by unclear and delayed guidance tied to changes in the Supplemental Nutrition Assistance Program, commonly known as SNAP, and concluded that enforcing penalties under those conditions would be unfair.
The dispute stems from changes included in the One Big Beautiful Bill Act, or H.R.1, which became law in July and narrowed SNAP eligibility for refugees, asylum recipients, and other noncitizens admitted through humanitarian programs. While the law took effect over the summer, the Agriculture Department did not issue detailed implementation guidance to states until Oct. 31. One day later, the agency announced it would end a 120-day grace period that protects states from financial penalties related to payment errors, a move that several states argued effectively left them no time to comply.
U.S. District Judge Mustafa T. Kasubhai said the late-issued guidance contributed to widespread confusion and lacked the clarity and consistency states rely on when implementing major eligibility changes. He pointed to what he described as a disconnect between the statute itself and the agency’s guidance, calling it further evidence of inadequate communication from the federal government. Kasubhai ruled that the grace period should be extended until April 9, 2026, giving states an additional four months to comply without facing financial penalties.
The lawsuit was brought by Washington state and joined by 20 other states and the District of Columbia, which argued that the federal government improperly started the compliance clock when the law was signed rather than when guidance was issued. The states also contended that the guidance went beyond the scope of the law and excluded categories of lawful residents not intended by Congress. During the hearing, attorneys for the states said that while eligibility questions had largely been resolved through follow-up guidance, the timing of enforcement remained the central issue.
State officials emphasized that updating eligibility systems is complex and time-consuming, often requiring major changes to outdated computer systems and staff training. They warned that error rates typically spike after major rule changes and that the new penalties are so severe that at least one state has considered withdrawing from SNAP entirely. The judge agreed that the states demonstrated credible and compelling evidence of irreparable harm, including financial strain, budget uncertainty, and the risk of disrupting food assistance for vulnerable residents.
Government attorneys argued that states had known about the law since July and that delaying enforcement would undermine congressional intent. They maintained that the Agriculture Department never intended to exceed the law’s requirements and said any confusion resulted from misunderstandings at the state level. Kasubhai rejected that argument, ruling that the law did not clearly equate the effective date with the implementation date and that such an interpretation would require explicit direction from Congress.
In his ruling, Kasubhai said the public interest favored preventing harm to people who rely on food assistance and allowing states a measured transition period to apply the new rules. He concluded that forcing immediate compliance under threat of steep penalties would risk real harm to families and undermine the stability of the SNAP program.