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Multi-State Coalition Sues USDA Over Mandatory SNAP Data Sharing

United States Department of AgricultureJuly 28, 2025New York Attorney General

Summary

New York Attorney General Letitia James, joined by 20 other states and Kentucky, filed a lawsuit challenging the Trump administration's policy requiring states to disclose personal information of SNAP recipients to federal agencies. The policy violates privacy laws by demanding sensitive data like Social Security numbers for potential immigration enforcement. The coalition seeks a court injunction to stop the illegal data sharing.

Remedy

The coalition is seeking a court order declaring the USDA's data demand illegal and enjoining the disclosure of SNAP recipients' personal information to other federal agencies for non-program purposes.

Injunction

Contract Impact

In-house legal teams should review all agreements where the company (as a state contractor, vendor, or data processor) handles SNAP or other public assistance program data. Focus on data sharing agreements, data processing addendums (DPAs), and any clauses governing the disclosure of personally identifiable information (PII) to federal agencies. Specific clauses to scrutinize include those permitting data sharing for 'program administration,' 'law enforcement purposes,' or 'compliance with federal directives.' Changes may be needed to explicitly prohibit the use of SNAP data for immigration enforcement absent a warrant or court order, require prior notice and an opportunity to object to such data transfers, and mandate data minimization (e.g., limiting shared data to only what is strictly necessary for SNAP administration). Contracts should also be updated to reflect the legal risks of complying with a potentially unlawful federal mandate and include indemnification provisions related to privacy violations.

Contract Search Terms

SNAP data disclosure requirementpersonal information sharing clauseSocial Security number transmissionimmigration enforcement data usedata retention schedule for assistance programsfederal data sharing mandatebenefit recipient privacy provisioncross-agency data transferlaw enforcement data accessprogram eligibility data sharing

Laws Cited

Administrative Procedure Act

Violation Types

Entity Details

Entity

United States Department of Agriculture

Also known as: USDA

Industry

Other

Multistate Coalition

ArizonaCaliforniaColoradoConnecticutDelawareHawaiiIllinoisMaineMarylandMassachusettsMichiganMinnesotaNevadaNew JerseyNew MexicoOregonRhode IslandWashingtonWisconsinDistrict of ColumbiaKentucky

Official Sources

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