The U.S. Department of Agriculture said states that gave full SNAP benefits in November to recipients after a lower court decision allowed them to do so should “immediately undo” the distributions and that failure to comply could result in the cancellation of future disbursements of federal funds.
“To the extent that states submitted full SNAP payment files for November 2025, this was not authorized. Accordingly, states must immediately undo any actions taken to issue full SNAP benefits for November 2025,” Patrick A. Penn, deputy assistant secretary for Food, Nutrition and Consumer Services, wrote on Saturday about the Supplemental Nutrition Assistance Program, or SNAP.
“Failure to comply with this memorandum may result in USDA taking various actions, including canceling the federal share of state administrative costs and holding states responsible for any overissues that result from noncompliance,” he wrote.
The latest memo was a reversal of earlier guidance the USDA had issued before the Supreme Court again halted the distribution of full SNAP benefits on Friday, sending the case back to the appeals court.
Friday’s memo said the relevant Trump administration agencies would “complete the necessary processes to make funds available to support their subsequent transmission of complete issuance files to their EBT processor.”
Saturday’s memo comes amid a rapidly moving legal battle over whether the federal government should continue to disburse SNAP benefits, also known as food stamps, to the more than 40 million Americans who normally receive them during the current federal government shutdown.
SNAP benefits were funded for October, the first month of the shutdown, but at the end of the month, the USDA posted a message on its website informing Americans that SNAP benefits would not be distributed in November, telling them that “the well has run dry” and blaming Democrats for the mistake.
Two separate lawsuits were filed before Nov. 1 in Rhode Island and Massachusetts to force the federal government to release the funds.
In response to one of the lawsuits, the USDA allowed SNAP benefits to be partially released. Then last week, a federal judge ordered the Trump administration to pay all SNAP benefits for November.
States began disbursing the funds as quickly as possible last week. But on Friday, the Supreme Court allowed the Trump administration to temporarily suspend SNAP payments for November.
Saturday’s USDA guidance did not explain to states how they should recover funds that have already gone to SNAP recipients.
On Sunday, Gov. Maura Healey, D-Mass., said SNAP recipients in her state should continue spending their funds and threatened to sue the Trump administration.
“If President Trump wants to penalize states for preventing Americans from going hungry, we will see it in court. Massachusetts residents with funds on their cards should continue to spend them on food. These funds were processed in accordance with guidance we received from the Trump Administration and a lower court order, and were processed prior to the Supreme Court’s order Friday night,” Healey said in a statement.
Gov. Tony Evers, D-Wis., responding to the USDA’s request to undo SNAP disbursements, simply said in a statement: “No.”
“Our administration is actively fighting in court against the Trump Administration’s efforts to withdraw food assistance from Wisconsin children, families and seniors, and we look forward to the court resolving this issue,” he added.
