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    Labor & Employment Law Daily Wrap Up, LITIGATION NEWS, TRENDS—Lawsuit filed over USDA’s purported termination of waiver of federal work requirements for certain SNAP recipients, (Oct 28, 2025)

    By Brandi O. Brown, J.D.

    The waiver was not set to expire until the end of February 2026.

    On October 3, 2025, a complaint filed by the Urban Justice Center-Safety Net Project (UC-SNP) alleges that USDA, “acting without any legal authority,” issued a notice indic ...

    By Brandi O. Brown, J.D.

    The waiver was not set to expire until the end of February 2026.

    On October 3, 2025, a complaint filed by the Urban Justice Center-Safety Net Project (UC-SNP) alleges that USDA, “acting without any legal authority,” issued a notice indicating it would prematurely terminate a waiver of federal work requirements for recipients of SNAP (Supplemental Nutrition Assistance Program) who are classified as Able-Bodied Adults Without Dependents (ABAWDs), effective November 2, 2025. That waiver, the complaint explains, had been approved to run through the end of February 2026 “based on a lack of sufficient jobs in 61 New York counties including the five boroughs of New York City.”

    Puts families at risk. Because of the agency’s actions, however, over 100,000 NYC SNAP recipients will receive notice in November that they must find employment or begin participating in federal work programs by December 1, 2025. Those who are unable to comply will risk termination of their benefits, which they use to feed themselves and their families.

    Impossible to implement. It will also impact the NYC Department of Social Services, the suit alleges, because “the abbreviated time frame presents innumerable obstacles to an orderly rollout of ABAWD time limits and work rules. DSS must immediately mail out 100,000 letters, translated into 15 languages, reconfigure four different computer systems, screen 100,000 clients for possible exemptions on top of over 50,000 already scheduled November appointments, and mandate that six newly-retained contractors schedule 6,200 work appointments per day in November.”

    The lawsuit contends that the federal agency’s action is not statutorily authorized and is actionable under the Administrative Procedure Act as contrary to law.

    UJC-SNP also filed a motion for a temporary restraining order and preliminary injunction, as well as for class certification.

    The lawsuit is No. 1:25-cv-08869-NRB.

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