Michigan is among a group of states that won a federal court case against the Trump administration on Thursday, blocking implementation guidelines on food assistance eligibility for non-citizens.
The states sued the U.S. Department of Agriculture, which oversees the Supplemental Nutrition Assistance Program (SNAP), over guidelines issued in response to changes made by the One Big Beautiful Bill Act. That law, signed by President Donald Trump last summer, revoked SNAP eligibility for many lawfully present non-citizens.
The states argued that guidance released by the USDA last fall inaccurately placed certain groups under even greater restrictions than enacted by Congress.
The states also challenged the USDA’s implementation of the required 120-day adjustment period. During that period, states can adapt to new eligibility requirements without facing potential financial penalties for erroneous payments. The USDA’s guidance, issued on October 31, 2025, retroactively set the adjustment period as beginning with the passage of the bill four months prior, and ending on November 1, just one day after the issuance of the guidance.
The states said that setting an adjustment period retroactively was out of line with longstanding policy and could result in hundreds of millions of dollars in financial penalties per state.
The USDA declined a request for comment. In a court filing, the agency said the eligibility guidance was intended as a quick reference and shouldn’t be interpreted to conflict with the law. The agency also defended its implementation of the adjustment period, saying that states should not wait for their guidance before working to follow the law.
On Thursday, September 17, a federal judge sided with Michigan and 21 other states, striking down the USDA’s guidelines and ruling that the agency’s adjustment period cannot begin before the issuance of an implementing memorandum.
The judge, Mustafa Kasubhai of the U.S. District Court of Oregon, wrote that the USDA had placed states “in an impossible situation” and then created “potentially ruinous financial penalties” for the “inability to overcome that impossibility.”
In a statement, Michigan Attorney General Dana Nessel wrote that she was “relieved the Court rejected the Trump administration’s transparent attempt to exclude certain residents from SNAP benefits in violation of eligibility criteria set by Congress.”
The ruling does not reverse eligibility restrictions implemented by the One Big Beautiful Bill Act. Those restrictions prohibit most non-permanent residents, including refugees and victims of trafficking, from accessing food assistance.
