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Whatever else it was about, a lawsuit that in recent weeks bumped through a federal district court in Eugene demonstrated the hazards of ambiguous writing.
To be sure, the Trump administration and its antagonists—such as the state of Oregon, one of the lead plaintiffs in the case—have set down their own narrative frames.
“This is a case about nothing,” lawyers for the U.S. Department of Justice wrote in a filing last week, chiding disingenuous state attorneys general for wasting everyone’s time. “There is no real dispute between the parties.”
The plaintiffs disagreed. “This,” Oregon and its allies wrote, “is a case about the chaos caused by ill-considered and illegal federal agency action that purported to unlawfully eliminate many thousands of immigrants from crucial subsistence benefits.”
Nominally, the case was about federal food benefits, and who should get them by law. But mainly, it offered a small window into the confusion plaguing state agencies that have been tasked—under a federal leadership that does not seem to sweat the administrative details—with carrying out arguably the greatest change to the social safety net in a generation.
The law ushering in this change is President Donald Trump’s One Big Beautiful Bill Act, which, among several other things, restricts many lawful immigrants’ eligibility for the Supplemental Nutrition Assistance Program, a benefit used by hundreds of thousands of Oregonians alone.
Months after the law’s July passage, the U.S. Department of Agriculture issued guidance for state SNAP administrators. The Oct. 31 document, Oregon and many other states would later recount, was “long awaited.” But, as they alleged in a Nov. 26 lawsuit, upon reviewing the guidance, state agencies quickly encountered problems—namely that it appeared to contradict the very law it purported to cite.
In short, the One Big Beautiful Bill Act restricted SNAP benefits for noncitizens, but not to the degree the new guidance seemed to be suggesting.
The confusion stemmed in large part from a table in the USDA document that was, at best, written very ambiguously.
The left column of this table was titled “Alien Group.” The right column contained information about these groups’ respective eligibility for SNAP benefits under the new federal law.
Lawful permanent residents, the table said, were “eligible,” though in some cases after a long delay.
Other groups, such as “Hmong or Highland Laotian Tribal Members,” were “not eligible unless an LPR”—a long-term permanent resident, or green card holder.
Meanwhile, other groups, such as “refugees,” were simply “not eligible.”
Given these contrasts, the states say, they understood the USDA to be claiming that someone who entered the U.S. as, say, a refugee would never be eligible for SNAP—even if they subsequently got a green card.
It was the kind of administrative distinction that could alter tens of thousands of lives.
In previous weeks, wrote Jessica Amaya Hoffman of the Oregon Department of Human Services, agency staff had been working hard to prepare to implement the One Big Beautiful Bill. But they found the new USDA guidance to be “inconsistent” with their understandings of the law, which they had been getting ready to apply.
In this regard, Oregon’s public servants were apparently not alone; other state administrators reported similar confusion.
Compounding the issue, the plaintiffs alleged, was the fact that the USDA ordered states to implement the guidance within a single day.
This, then, raised separate concerns of administrative malfeasance. The states cited a federal law establishing a 120-day period for implementing new agency guidance. They said the issue was that complex changes such as those demanded by the One Big Beautiful Bill tended to result in a higher rate of errors. And given, they said, that the new law would impose potentially billions of dollars in additional costs when SNAP error rates veered too high, the risks were substantial.
On such terms, the case proceeded in Eugene under Judge Mustafa T. Kasubhai, a Biden appointee. Then, a few days ago, came a development: The USDA had issued fresh guidance.
As the plaintiffs pointed out, the new USDA document made clear what the initial October guidance did not: Lawful permanent residents were generally eligible for SNAP benefits, even if they’d initially entered the U.S. under humanitarian programs—as refugees, for example. On this front at least, the feds and the states were now on the same page after all.
In a subsequent court filing on Dec. 12, federal lawyers said that in fact this had always been the case. Plaintiffs “pretend” that USDA guidance had restricted SNAP benefits in ways contrary to law, they wrote. “This suit is a waste of the Court’s time.”
The plaintiffs agreed that, as far as the SNAP restrictions, the parties were no longer at odds. But to them this was a new development. “Defendants,” they wrote, “all but concede the guidance was contrary to law by having promulgated new guidance that revises the exact points on which the guidance was erroneous.”
Under the new status quo, the plaintiffs said, the judge’s intervention was mostly no longer necessary. There was one more wrinkle, however.
The Trump administration argued states should have to implement its guidance promptly—and in fact, should have implemented it months prior. States that had not done this feared they would ultimately be dinged with a higher SNAP benefits error rate, and face a wave of “catastrophic new penalties.”
Thus, a few days ago, Oregon and other states made a more specific ask of Judge Kasubhai: They wanted until April before feds could begin tallying certain errors against them.
In an order Monday, the judge granted this request.
