SFALP Students Act To Protect Food Stamp Eligibility For Vulnerable Families

When the U.S. Department of Agriculture proposed a change to the rules governing food stamp eligibility that would harm thousands of San Francisco families, students in the San Francisco Affirmative Litigation Project (SFALP) at Yale Law School sprang into action. They helped attorneys in the San Francisco City Attorney’s Office (SFCAO) write a public comment explaining why the proposed rule is “not just misguided, cruel, and harmful — but also unlawful.” Under the Administrative Procedure Act, the agency must consider the comments before finalizing the rule. The comments become part of the administrative record and are often used in subsequent litigation.

“The Trump Administration’s harmful policies need to be challenged through a variety of legal mechanisms,” said Shannon Manley ’20. “Having worked on litigation matters in my first two years in SFALP, it’s exciting to learn a new skill to add my legal toolkit.”

Students helped craft the comment from the beginning, researching and crafting legal arguments and then drafting a substantial portion of the comment itself. The comment explains why the proposed rule “violates fundamental separation of powers principles by making policy changes via executive fiat that Congress has repeatedly rejected,” and “violates the Administrative Procedure Act (APA) by failing to consider important aspects of the issue — such as the primary objectives of the [Supplemental Nutrition Assistance Program (SNAP)] program and the fact that the Proposed Rule will undermine them.” The comment — one of more than 75,000 submitted nationwide — details how the proposed rule would harm the most vulnerable San Francisco families and frustrate the city’s mission to end food insecurity.

“Taking food from hardworking families is a new low for an administration that cuts taxes for billionaires,” said San Francisco City Attorney Dennis Herrera. “The SNAP program is a lifeline for thousands of San Francisco households. If this rule takes effect, families won’t be able to put enough food on the table. They’ll also have less money for other necessities, like health care and housing. I want to thank the students in the San Francisco Affirmative Litigation Project for all of their hard work and assistance on this crucial matter.”

“In my nonprofit legal services work, I’ve seen how low-income families rely on critical SNAP benefits to feed their families,” said Melissa Fich ’21, “so it was incredibly important to me to highlight the proposed rule's effects on vulnerable people.”

“I’m grateful that the clinic gave me the opportunity to parlay outrage over the policy into a tangible action resisting it,” added Duncan Hosie ’21. “This is why we came to law school: to not just read about injustice, but also to partner with people to fight it. The Deputy City Attorneys approached the legal issues with poise and compassion, and collaborating with them on such an important issue was a wonderful experience.”