Eighth Circuit lifts injunction on Missouri’s SNAP implementation

The three-judge panel also overturned part of a summary judgment in favor of three individuals who claim their constitutional rights were violated.ST. LOUIS (CN) — The Eighth Circuit threw out Wednesday part of a summary judgment and an injunction in favor of a group of plaintiffs who claim Missouri’s SNAP program systematically failed them.The Supplemental Nutrition Assistance Program, known as SNAP, is a federally funded program overseen by the U.S. Department of Agriculture that provides low-income households with a monthly benefit to purchase food. Three individual plaintiffs and an advocacy group, Empower Missouri, filed a lawsuit in 2022, claiming Missouri’s method of vetting families for the program violates federal law and deprives them of SNAP benefits, including denials based solely on missed interviews and issues reaching the state’s resource center.In May 2025, Senior U.S. District Judge M. Douglas Harpool imposed an injunction to remedy the state’s systemic SNAP failures by reducing call wait times and streamlining the interview process.Missouri and Jessica Bax, the director of the Missouri Department of Social Services, appealed to the Eighth Circuit, arguing the plaintiffs lacked standing and the lower court erred in granting the summary judgment and injunction.The three-judge panel lifted the injunction.“Failure to consider the presence of an adequate remedy at law was not the only problem with the District Court’s permanent injunction analysis,” U.S. Circuit Judge Bobby E. Shepherd, a George W. Bush appointee, wrote in the 26-page opinion. “The District Court also ordered sweeping, overbroad relief, requiring Bax to make systemic changes to the SNAP benefits program in Missouri, which would affect all SNAP applicants in the state, not just the plaintiffs in this suit.”The appeals court also found the lower court erred in granting summary judgment on the plaintiffs’ SNAP claims.“Although determining ‘whether a statutory violation may be enforced through § 1983 ‘is a different inquiry than that involved in determining whether a private right of action can be implied from a particular statute[,]’ … the inquiries overlap in one meaningful respect — in either case we must first determine whether Congress intended to create a federal right,’” Shepherd wrote. “Because we determined that Congress did not intend to create a federal right in the SNAP Act, plaintiffs cannot maintain an independent cause of action under the SNAP Act either.”The appeals court did uphold the lower court’s granting of summary judgment on the plaintiffs’ due process and Americans with Disabilities Act claims.Caroline M. Brown of D.C.-based Brown & Peisch represented Bax before the appeals court. She spent most of the April hearing arguing the plaintiffs lack standing.The lack of standing claims against the individual plaintiffs — in which Brown argued they received their benefits so there was no harm — fell flat with the Eighth Circuit. But the argument that Empower Missouri’s decision to divert resources to an issue doesn’t create a harm had little sway with the court.“Although plaintiffs contend that Bax’s conduct frustrates Empower Missouri’s ‘core business activities,’ its alleged injury consists solely of the time and money it spent responding to Bax’s administration of SNAP,” Shepherd wrote. “This is not enough to establish standing.”Katharine Deabler-Meadows represented the plaintiffs from the New York City-based National Center for Law and Economic Justice. In an emailed statement to Courthouse News, the senior attorney said, “We are encouraged that the Eighth Circuit affirmed that depriving our clients of their SNAP benefits and ADA accommodations violates the law. We are assessing next steps to ensure that Missouri’s Department of Social Services complies with their legal obligations going forward.”Brown did not immediately respond to an email seeking comment.U.S. Circuit Judges David R. Stras, a Donald Trump appointee, and James B. Loken, a George H.W. Bush appointee, joined Shepherd on the panel. The Eighth Circuit remanded the case to the lower court for further proceedings.Subscribe to our free newslettersOur weekly newsletter Closing Arguments offers the latest about ongoing trials, major litigation and rulings in courthouses around the U.S. and the world, while the monthly Under the Lights dishes the legal dirt from Hollywood, sports, Big Tech and the arts.Additional Reads