In a chaotic 24-hour span that left millions of Americans uncertain about their food assistance, the federal government issued conflicting directives about November SNAP benefits—first ordering full funding, then reversing course after the Supreme Court intervened.

On Friday, November 7, 2025, the U.S. Department of Agriculture sent a memo to state SNAP agencies announcing it was “working towards implementing November 2025 full benefit issuances” to comply with a federal court order. The directive came after U.S. District Judge John McConnell in Rhode Island mandated on Thursday that the Trump administration fully fund the Supplemental Nutrition Assistance Program for November by Friday, rejecting the administration’s earlier plan to provide only 65% of benefits.

Deputy Under Secretary Patrick Penn informed regional directors that the USDA would “complete the processes necessary to make funds available” later that day to support states transmitting “full issuance files to your EBT processor.” The order required the administration to tap both the SNAP contingency fund and additional Section 32 funds from the Agricultural Adjustment Act to cover the approximately $8.2 billion cost of November benefits.​

Several states quickly acted on the federal guidance. Pennsylvania, New York, Massachusetts, Oregon, Wisconsin, Connecticut, and New Jersey began processing and issuing full SNAP benefits to recipients Friday. Governor Josh Shapiro of Pennsylvania announced that recipients whose payments had been delayed would see their cards reloaded by midnight Friday. Connecticut Governor Ned Lamont authorized state funding as a backstop should federal funds not materialize.

The Trump administration immediately challenged Judge McConnell’s ruling, arguing it “makes a mockery of the separation of powers.” After the First Circuit Court of Appeals denied a request for an administrative stay Friday evening at 6:08 p.m., the administration filed an emergency application with the Supreme Court.​

At 9:17 p.m. EST Friday, Justice Ketanji Brown Jackson issued an administrative stay temporarily blocking the district court’s order. The stay gave the First Circuit Court of Appeals time to consider the Trump administration’s full request for a stay pending appeal, with Justice Jackson’s order set to expire 48 hours after the appeals court ruled.​

Solicitor General John Sauer had warned the justices that “without intervention from this Court, they will have to ‘transfer an estimated $4 billion by tonight’ to fund SNAP benefits through November.” The Justice Department argued that the funding lapse “is a crisis occasioned by congressional failure and one that can only be solved through congressional action.”

Late Saturday night, November 8, the USDA issued a new memo—obtained in the attached images—reversing Friday’s guidance. The memorandum stated unequivocally that “States must not transmit full benefit issuance files to EBT processors” and must instead “continue to process and load the partial issuance files that reflect the 35 percent reduction of maximum allotments.’​

Most significantly, the memo declared that states sending full SNAP payment files “was unauthorized” and ordered: “Accordingly, States must immediately undo any steps taken to issue full SNAP benefits for November 2025.’​

The directive included a stark warning: “Per 7 CFR 271.7(h), 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.’​

The memo referenced the Supreme Court’s administrative stay of Judge McConnell’s orders in Rhode Island State Council of Churches, et al. v. Rollins, 25-cv-569.

For states that had already processed full benefits based on Friday’s guidance, the Saturday directive posed significant operational and legal challenges. The reversal left officials scrambling to determine whether they could “claw back” benefits already loaded onto recipients’ electronic benefit transfer cards.​

Ohio had announced on Friday that it expected to begin distributing full benefits by the week of November 10, only to receive the conflicting Saturday guidance. The Ohio Department of Job and Family Services had stated it was working with vendors to process the payments for approximately 1.4 million Ohioans who receive about $264 million monthly in SNAP benefits.​

Food banks nationwide reported surging demand as the crisis unfolded, with many warning of potential public health emergencies. Some states, including New Jersey, had declared states of emergency in response to the funding lapse.

The administration initially agreed to use $4.65 billion from the SNAP contingency fund to cover 65% of maximum allotments, down from an initial plan for 50%. But Judge McConnell ruled Thursday that partial payments were “arbitrary and capricious” and ordered full funding using both contingency funds and Section 32 money.

The case now rests with the First Circuit Court of Appeals, which must rule on the Trump administration’s stay request. Justice Jackson’s administrative stay will terminate 48 hours after that decision.