Garnett v. Zeilinger

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA SHONICE G. GARNETT et al., Plaintiffs, v. Case No. 17-cv-1757 (CRC) LAURA ZEILINGER, Defendant. MEMORANDUM OPINION AND ORDER Plaintiffs—recipients of Supplemental Nutrition Assistance Program benefits in the District of Columbia—filed this putative class action against the director of the District’s benefit program. They allege several violations of the federal requirements for administration of the program. Plaintiffs now seek to certify two classes of District benefits recipients. Finding that the resolution of their motion is governed by the D.C. Circuit’s recent decision in D.L. v. District of Columbia (“D.L. II”), 860 F.3d 713 (D.C. Cir. 2017), the Court will grant their motion, though it will certify three classes instead of two. I. Factual Background A. The Supplemental Nutrition Assistance Program (“SNAP”) Congress originally enacted the Supplemental Nutrition Assistance Program (“SNAP”) in 1964, seeking to combat hunger and malnutrition by assisting low-income households in purchasing food. See Food Stamp Act of 1964, Pub. L. No. 88-525, 78 Stat. 703 (codified at 7 U.S.C. §§ 2021 et seq.).1 A household is typically eligible for SNAP benefits if its net income is 1 The program began as the “Food Stamp Program” and the name was changed to SNAP in 2008. See Food, Conservation, and Energy Act of 2008, Pub. L. No. 110-234, § 4001, 122 Stat. 923, 1092. below the federal poverty line and its resources generally do not exceed $2,000. 7 U.S.C. § 2014(c), (g). Within the federal government, the Secretary of Agriculture has delegated most of the administration of SNAP to the federal Food and Nutrition Service (“FNS”), an agency within the Department of Agriculture. 7 C.F.R. § 271.3. Responsibility for administering SNAP is shared between the federal government and the States. The federal government provides the funding for benefits and covers 50 percent of administrative costs. 7 U.S.C. §§ 2013(a), 2025. States can elect to participate in the program and, if they do, are responsible for certifying household eligibility, issuing benefits, and otherwise administering the program on the state level. Id. §§ 2013(a), 2020(a)(1); 7 C.F.R. § 271.4. If a State elects to participate, it must administer its SNAP program in accordance with the relevant statutes and the Secretary of Agriculture’s regulations. 7 U.S.C. § 2020(e); 7 C.F.R. § 273.2. Part of these requirements involve the procedure for processing applications for SNAP benefits. For instance, States must allow a household to apply for SNAP benefits the same day that it contacts a SNAP program office in person during office hours. 7 U.S.C. § 2020(e)(2)(B)(iii). Once a State receives an application for benefits, it must “promptly” certify a household’s eligibility. Id. § 2020(e)(3). This certification process must be completed and benefits provided no later than thirty days after the application’s filing. Id. For certain households with extremely low income—less than $150 per month or liquid resources less than $100—the State must provide benefits no later than seven days after an application is filed. Id. § 2020(e)(9)(A). These are known as “expedited” applications. Eligible ...

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