The U.S. Department of Agriculture said that states that issued full November SNAP benefits to recipients after a lower court decision allowed them to should “immediately undo” the distributions and that failure to comply could result in cancellation of future disbursement of federal funds.
“To the extent States sent full SNAP payment files for November 2025, this was unauthorized. Accordingly, States must immediately undo any steps taken to issue full SNAP benefits for November 2025,” Patrick A. Penn, the Deputy Under Secretary Food, Nutrition, and Consumer Services, wrote on Saturday regarding the Supplemental Nutrition Assistance Program, or SNAP.
“Failure to comply with this memorandum may result in USDA taking various actions, including cancellation of the Federal share of State administrative costs and holding States liable for any overissuances that result from the noncompliance,” he wrote.
The latest memo was a reversal of earlier guidance the USDA had issued before the Supreme Court again paused the distribution of full SNAP benefits on Friday, sending the case back to the appeals court.
The Friday memo said that the relevant agencies in the Trump administration would “complete the processes necessary to make funds available to support your subsequent transmittal of full issuance files to your EBT processor.”
Saturday’s memo comes amid a fast-moving legal battle over whether the federal government should continue to disburse SNAP benefits — also known as food stamps — to over 40 million Americans who usually receive them during the ongoing 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 wouldn’t be dispersed in November, telling them that “the well has run dry” and blaming Democrats for the lapse.
Two separate lawsuits were filed in Rhode Island and Massachusetts ahead of Nov. 1 seeking 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 SNAP benefits in full for November.
States began to disburse the funds as quickly as possible last week. But on Friday, the Supreme Court allowed the Trump administration to temporarily halt SNAP payments for November.
The USDA guidance on Saturday did not explain to states how they should claw back funding that may have already gone out to SNAP recipients.
On Sunday, Gov. Maura Healey, D-Mass., said that SNAP recipients in her state should continue to spend 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 him in court. Massachusetts residents with funds on their cards should continue to spend it on food. These funds were processed in accordance with guidance we received from the Trump Administration and a lower court order, and they were processed before the Supreme Court order on Friday night,” Healey said in a statement.
Gov. Tony Evers, D-Wis., in response to the USDA’s request to undo SNAP disbursements, simply said in a statement, “No.”
“Our administration is actively in court fighting against the Trump Administration’s efforts to yank food assistance away from Wisconsin’s kids, families, and seniors, and we are eager for the court to resolve this issue,” he added.
