A federal court has prohibited the Trump administration from terminating Supplemental Nutrition Assistance Program (SNAP) benefits in Minnesota, citing the imposition of “entirely new conditions” as the basis for its decision.

In December 2025, the U.S. Department of Agriculture (USDA) issued a warning to Minnesota, demanding that the state recertify all SNAP recipients in specific counties by January 15, 2026. The USDA threatened to initiate noncompliance procedures if the state failed to meet the deadline.

In response, Minnesota filed a lawsuit, arguing that the USDA exceeded its authority and violated constitutional provisions as well as the Administrative Procedure Act (APA), which regulates federal agency actions.

On Friday, U.S. District Judge Laura M. Provinzino, appointed by President Joe Biden, granted a preliminary injunction. This ruling prevents the USDA from penalizing Minnesota over the recertification demand and prohibits any federal interference with the state’s SNAP benefits allocation for the first quarter of 2026.

“Minnesota has consistently adhered to federal laws in its SNAP recertification process, with USDA’s approval,” the court order stated. “The Recertification Letter and Enforcement Letter disrupt this established procedure without justification, demanding that Minnesota implement a new process within 30 days. Such arbitrary decision-making is exactly what the APA seeks to prevent and what a preliminary injunction is designed to rectify.”

In ruling against the government, the court preliminarily accepted several of the plaintiffs’ legal arguments – particularly the notion that USDA’s actions were “arbitrary and capricious,” an APA-sourced term of art which refers to agency actions that go too far while simultaneously eschewing formal, mandatory processes.

From the ruling, at length:

Minnesota and the Recertification Counties put forth evidence that requiring them to comply with the Recertification Letter’s demands would be close to impossible, as it would require the four counties to divert nearly all available resources and expend additional resources to even come close to meeting the Recertification Letter’s deadline…

That leaves the distinct impression that the USDA has set Minnesota and the Recertification Counties up to fail, a consequence that is about as arbitrary as they come.

The court goes on to note that, under APA precedent, when a federal agency “drastically changes its own policies and practices,” it is the agency’s burden to “consider the alternatives” that are “within the ambit of the existing” policy. Such an inquiry must take into account “whether there were reliance interests, determine whether they were significant, and weigh any such interests against competing policy concerns,” the judge explained.

“The USDA did none of this,” Provinzino writes. “Instead, it pulled the rug out from under Minnesota without offering any reasoned explanation or one that considered the weight of its new demands. Minnesota is accordingly likely to prevail on its claim that the Recertification Letter (and the companion Enforcement Letter) is arbitrary and capricious.”

At this stage, while ruling on the aforementioned APA claim in the plaintiffs’ favor, the court did not consider the remaining claims.

Still, the judge took some time to opine on the nature of the Trump administration’s underlying requests – finding them legally lacking.

“The Recertification Letter violates [several statutory] mandates because the Recertification Letter requires Minnesota to end every SNAP recipient’s certification period before its ‘assigned termination date,’” the order goes on. “Terminating a SNAP recipient’s guaranteed certification period, for reasons wholly unrelated to the recipient’s eligibility or conduct, is fundamentally unfair because it defeats the recipient’s reasonable reliance on the guarantee of uninterrupted benefits during that period.”

In their 48-page complaint, the plaintiffs sketched out a similar notion.

“Defendants are threatening to withhold Minnesota’s SNAP administrative funding and to disallow its participation in SNAP altogether unless Minnesota completes the impossibly onerous tasks they have demanded,” the lawsuit reads. “This violates the constitutional limitations on the federal government’s spending power because Minnesota did not have ‘clear notice’ of this condition when it elected to participate in SNAP.”