Trump Administration Orders States to Reverse Full SNAP Payouts

What We Know

• Amid the federal government shutdown beginning November 1, 2025, the U.S. Department of Agriculture (USDA) initially directed states to issue reduced benefits, but then a federal court ordered full payments.
• Last week, two temporary restraining orders (TROs) were issued by a federal district judge, Judge John McConnell Jr., one with a deadline of November 5 and the second (to pay full SNAP benefits) with a deadline of November 7, when the first deadline was not met. (More on the full legal timeline below)
• Today, November 9, USDA sent a memo instructing states to undo any full‑benefit payments made under the court order, saying those payments were “unauthorized” and warning states they might face penalties or loss of administrative funds.
• Dozens of states warn that having already issued full benefits (or committed to them) places them at risk of massive over‑payment liabilities and fiscal chaos.

TL;DR: The Trump administration has abruptly reversed course on full SNAP payments, demanding that states reverse payouts made last week under Judge McConnell’s court order, triggering a legal and potential economic crisis for food assistance programs nationwide.

What’s Going On

For families who depend on SNAP, this uncertainty could mean sudden benefit reductions, further delays, or even the need to return funds previously provided. Food banks and state-level providers are already sounding “catastrophic” alarm bells.

The Legal Landscape & Timing

The sequence is chaotic and concerning on multiple levels.

Because of the government shutdown, federal SNAP funding expired on November 1. The USDA initially signaled that states could not issue full payments and would need to rely on limited contingency funds. Below is a summary of the court proceedings and oral orders that have since followed:

1. States and advocacy groups sued the Trump administration over the funding of SNAP benefits. On October 31, Judge John McConnell Jr., a district court judge in Rhode Island, gave the administration two options: either use SNAP contingency funds for November payments (which did not have enough funding to pay full benefits), or tap other section 32 funding (such as State Child Nutrition Programs) for payments. Either choice was to be communicated by November 3 and released by November 5. Note: A Massachusetts judge ordered similarly on the same day, but Judge McConnell’s order took things a step further.

2. The Trump administration/USDA agreed to pay partial payments on Monday, November 3, but by November 5, payments were not released. In another hearing on November 6, Judge McConnell stated the administration had not complied with his earlier order and submitted another TRO requiring full November payments by Friday, November 7.
3. The USDA immediately appealed Judge McConnell’s TROs to the U.S. Court of Appeals, which denied their request for a stay on the TROs while the Court of Appeals decided on the case. The administration then appealed the Court of Appeals’ denial of the Application to Stay to the Supreme Court of the United States (SCOTUS).
4. Justice Ketanji Brown Jackson granted that order pending further proceedings with a deadline of 48 hours.
5. In response to Justice Jackson’s temporary stay, on November 9, the USDA sent guidance telling states that any full payment files submitted were unauthorized and “must immediately undo any steps taken to issue full SNAP benefits for November 2025.”

States that relied on the court order and have already loaded benefits onto EBT cards (for example, Wisconsin) now face the prospect of being told to reverse the payments or cover the over‑issuance themselves. The USDA warns that non-compliance could result in the cancellation of federal funding or states’ liability for “over‑issuances.”

Here are a few key legal elements:

• The SNAP program is federally funded but state-administered under USDA oversight. It is one of the federally funded food assistance programs, with others included in section 32 funding.
• The shutdown resulted in the lapse of federal appropriations for SNAP, raising the question of whether USDA has legal authority to fund full benefits from contingency funds or other buckets, given the constitutional separation of powers and Congress having the power of the purse.
• The USDA’s memo to states characterizes payments made under the court order as “unauthorized,” suggesting the court-ordered mandate is no longer backed by valid funding.
• States have limited time: If they issue full payments and the federal government later refuses reimbursement, states may be legally/financially responsible for overpayments.

The current stay means the November 6 district‑court mandate is not currently enforceable. That stay, however, is a temporary order to allow time for the Court of Appeals process to play out. These back-and-forth orders and memos between the judicial and executive branches leave states holding the bag and households sitting in the uncertainty of what to do and how to put food on the tables of millions of Americans.

Importantly, the administration’s legal justification revolves around appropriations law (whether funds exist), administrative authority, and whether emergency/contingency funds can cover full payments absent a valid appropriation. Because a full courtroom resolution can take months, states are caught between issuing benefits (and risking overpayment liability) or reducing/withholding and risking lawsuits/chaos.

What’s at Stake for Communities

For communities already facing food insecurity, this is more than political gymnastics. Millions rely on SNAP as a lifeline. When guidance shifts so rapidly and states are asked to reverse payments, the consequences are immediate: grocers, bodegas, community food banks, and families will feel it – some more than they already have.

Historically, those disproportionately dependent on SNAP are due to systemic economic inequality, wage gaps, and food deserts. Cuts, delays, or reversals in benefits exacerbate those disparities. When the federal government uses funding uncertainty as a leverage point, it effectively places vulnerable communities at risk.

Moreover, the legal limbo — states facing threats of claw-backs, vendors unpaid, funds uncertain — triggers operational instability in the networks that serve marginalized populations. Food pantries may run out of resources, local grocers may face unpaid EBT claims, and state agencies may divert funds from other services to cover shortfalls.

In the bigger picture, this episode underscores how hunger policy can be turned into a political lever rather than a stable safety‑net for the families who need it most. For advocates working in impacted communities, it signals the continual need for local contingency planning, stronger state-level safeguards, and advocacy for clarity in federal funding commitments. A burden community leaders and organizers already know too well and carry too often.