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TIER A Purges & Agencies
Documented incident

Demanding every state's SNAP recipient data, and threatening food-aid funding over it

Scores: V 84, C 75, scored on September 27, 2026
Institutional outcome
USDA is barred from withholding SNAP funding from the plaintiff states for declining to produce the data, and from enforcing the renewed demand. Roughly half the states, mostly Republican-led, had already submitted the records, so millions are in federal hands. The Secretary announced that USDA would withhold benefits from noncompliant states, an escalation the court blocked. A parallel suit brought by nonprofits, Pallek v. Rollins, is pending.
What happened

A March 2025 executive order directed federal agencies to obtain unfettered access to data held by state programs receiving federal funds. USDA published a system-of-records notice on June 23, 2025 for a National SNAP Information Database, and on July 9 demanded that states produce virtually all SNAP applicant and recipient data back to 2020: names, Social Security numbers, dates of birth, addresses, household financial information, and five years of electronic benefit transaction records. The Inspector General separately demanded all 2024 participant data from California, Illinois, and Michigan. States that refused were threatened with the loss of administrative funding. In more than sixty years of the federal-state SNAP partnership, USDA had relied on anonymized data and samples for oversight. The department's position, echoed by the America First Policy Institute, is that the absence of recipient-level data prevents it from detecting fraud and duplicate enrollment, and that improper payments have risen.

Twenty-one states and the District of Columbia sued on July 28, 2025 under the Administrative Procedure Act, the Privacy Act, and the E-Government Act. Judge Maxine Chesney entered a temporary restraining order on September 19 and a preliminary injunction on October 15. She held that the provision USDA invoked, 7 U.S.C. 2020(a)(3), permits disclosure only subject to data and security protocols agreed to by the state agency and the Secretary, which she read as a procedural bar; that the statute's language is permissive rather than mandatory; and that USDA had demanded information the states never obtained from applicant households. She found the states likely to suffer irreparable harm and enjoined USDA from disallowing SNAP funding over the refusal.

On November 24, 2025, USDA sent the states a renewed demand, attaching what it called a proposed data and security protocol while stating there could be no good-faith objections to it. The Secretary announced that USDA would withhold SNAP benefits from states that did not comply. The states moved to enforce or expand the injunction, and on February 26, 2026 the court granted the motion in part, barring USDA from withholding administrative funding over the renewed demand and finding the states likely to succeed because the agency had not established a mutually agreed protocol. The rulings are preliminary, the merits await a complete administrative record, and the government's program-integrity rationale is a real one that the court has not rejected. The transfer of Medicaid data is documented at SDA-09, the IRS transfer of taxpayer addresses at SDA-03, and the cross-agency search layer at SDA-08.

Evidence status
Documented; a temporary restraining order, a preliminary-injunction opinion, and an order expanding it after the demand was renewed
Legal status
California v. U.S. Dept. of Agriculture, No. 3:25-cv-06310 (N.D. Cal.), Judge Maxine M. Chesney. TRO September 19, 2025; preliminary injunction October 15, 2025 finding the states likely to succeed under the Administrative Procedure Act; order expanding the injunction February 26, 2026 after USDA reissued the demand. The merits are not finally decided
Dates
Executive order on data access 2025-03; system-of-records notice 2025-06-23; demand issued 2025-07-09; suit filed 2025-07-28; TRO 2025-09-19; preliminary injunction 2025-10-15; renewed demand 2025-11-24; injunction expanded 2026-02-26
Key actors
Sources
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