Filed Date: Oct. 27, 2025
Case Ongoing
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This case challenged the U.S. Department of Agriculture’s (USDA) abrupt termination of a waiver of federal work requirements for recipients of Supplemental Nutrition Assistance Program (SNAP) who are classified as Able-Bodied Adults Without Dependents (ABAWDs).
The ABAWD waiver was granted on October 2, 2024, and was approved to remain in effect until February 28, 2026, due to insufficient job opportunities in 61 New York counties, including all five boroughs of New York City. However, on October 3, 2025, USDA issued a notice that the ABAWD waiver would be terminated as of November 2. This meant that those receiving SNAP under the ABAWD waiver program would need to find employment or participate in approved federal work programs by December 1 or risk termination of their SNAP benefits.
On October 27, 2025, the Urban Justice Center’s Safety Net Project and New York City resident Laeticia Miguel brought this class action against Secretary of the USDA in U.S. District Court for the Southern District of New York, Brooke Rollins. Plaintiffs sought to block the premature termination of New York’s SNAP ABAWD waiver. They cited the NYC Human Resources Administration’s estimate that over 100,000 individuals classified as ABAWD would immediately become subject to work requirements on November 2. Additionally, plaintiff, Laeticia Miguel, a caretaker for her disabled husband, claimed that she and her husband would struggle to survive on only SNAP benefits for one person, and that with such sudden termination of the program, she would not have the time needed to figure out alternatives in time to continue feeding them both.
Plaintiffs argued that the premature termination of the ABAWD waiver was not legally authorized, specifically referencing the SNAP Act in the “Big Beautiful Bill” Act of 2025, USDA’s regulations, and the language of New York’s ABAWD waiver granted by USDA in 2024. Filing under the Administrative Procedure Act (APA), plaintiffs alleged that USDA’s early revocation of New York’s ABAWD Waiver was contrary to law because it exceeded USDA’s legal authority, and was arbitrary and capricious because the agency failed to consider important effects of its action or provide a reasoned explanation. Plaintiffs sought class certification for all New York City SNAP recipients classified as ABAWD. They also sought a declaratory judgment that USDA violated the APA, a preliminary and permanent injunction barring enforcement of the termination until February 28, 2026, attorneys’ fees, and other equitable relief. The case was assigned to Judge Naomi Reice Buchwald.
Also on October 27, plaintiffs filed an emergency motion for a temporary restraining order (TRO) and a motion for a preliminary injunction, urging the court to stay the termination of New York’s ABAWD waiver and to certify plaintiffs’ requested class. They cited precedent that stated that a “loss of even a small portion of welfare benefits can constitute irreparable injury” warranting emergency relief. Thousands of plaintiffs like Ms. Miguel faced a more imminent threat of not being able to feed themselves due to the program’s termination. The Urban Justice Center would also be forced to divert already scarce resources to assist those impacted by USDA’s termination. These irreparable injuries satisfied the standard for granting emergency relief. Additionally, plaintiffs asserted that they were likely to succeed on the merits because this action violated the law, and, under the APA, courts can set aside agency action that violates the law. Finally, plaintiffs claimed that the balance of hardships tipped toward plaintiffs because the harm USDA might suffer from three extra months of the ABAWD waiver program, as was initially planned, was not nearly as great as the harm that plaintiffs stood to face from abrupt and premature termination of the program.
This case is ongoing.
Summary Authors
Madeline Kaplan (10/29/2025)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/71771421/parties/urban-justice-center-safety-net-project-ujc-snp-v-rollins/
Buchwald, Naomi Reice (New York)
Josephson, Edward Joseph (New York)
Krishnaswamy, Pavita (New York)
Rahman, Laboni (New York)
Kornreich, Mollie Melissa (New York)
See docket on RECAP: https://www.courtlistener.com/docket/71771421/urban-justice-center-safety-net-project-ujc-snp-v-rollins/
Last updated Nov. 6, 2025, 10:11 a.m.
State / Territory:
Case Type(s):
Public Benefits/Government Services
Special Collection(s):
Trump Administration 2.0: Challenges to the Government
Key Dates
Filing Date: Oct. 27, 2025
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
Plaintiffs included the Urban Justice Center's Safety Net Project, a nonprofit program which fights "attacks on our social safety net" including homelessness and an individual, Laeticia Miguel, who relied on the New York's SNAP ABAWD waiver. Plaintiffs also asked the court to certify a class for all New York City SNAP recipients classified as ABAWD.
Plaintiff Type(s):
Non-profit NON-religious organization
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Pending
Defendants
Defendant Type(s):
Case Details
Causes of Action:
Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.
Other Dockets:
Southern District of New York 1:25-cv-08869
Available Documents:
Outcome
Prevailing Party: None Yet / None
Relief Granted:
Source of Relief:
Issues
Benefits (Source):