Tesfa v. United States

CourtDistrict Court, E.D. Washington
DecidedJuly 17, 2020
Docket2:19-cv-00073
StatusUnknown

This text of Tesfa v. United States (Tesfa v. United States) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tesfa v. United States, (E.D. Wash. 2020).

Opinion

1 EASTERN DISTRICT OF WASHINGTON Jul 17, 2020

2 SEAN F. MCAVOY, CLERK

3 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 4 SOUTH HILL MARKET, a No. 2:19-cv-00073-SMJ 5 Washington entity; GEDION TEKLEMARIAM TESFA, an ORDER GRANTING 6 individual; and OGBAI DEFENDANTS’ MOTION FOR GEBREMICHAEL TESFU, an SUMMARY JUDGMENT 7 individual,

8 Plaintiffs,

9 v.

10 UNITED STATES and U.S. DEPARTMENT OF AGRICULTURE 11 (USDA),

12 Defendants.

13 Before the Court, without oral argument, is Defendants’ Motion for Summary 14 Judgment, ECF No. 26. Plaintiffs, who own and operate a small market in Spokane, 15 appeal their permanent disqualification from the Supplemental Nutrition Assistance 16 Program (“SNAP”) after an investigation found they engaged in prohibited 17 transactions involving SNAP benefits. Because the Court finds Plaintiffs have failed 18 to produce evidence from which a rational finder of fact could find that the 19 transactions resulting in their disqualification were legitimate, the Court grants 20 Defendants’ motion for summary judgment. 1 BACKGROUND 2 Plaintiffs Gedion and Ogbai Tesfa own and operate the South Hill Market

3 (the “Market”), a gas station and small market located in the South Hill 4 neighborhood of Spokane. See ECF No. 28 at 3. The Market occupies 5 approximately 5200 square feet and sells a variety of staple foods, snacks and

6 beverages, and other merchandise. See AR1 50, 57–67. In 2015, the Market received 7 approval from the United States Department of Agriculture (“USDA”) to participate 8 in the Supplemental Nutrition Assistance Program (“SNAP”). AR 2, 13–14. 9 A. The SNAP Program

10 SNAP is a program funded by the federal government to assist low-income 11 households in securing adequate food. See 7 U.S.C. § 2011. Each month, income- 12 qualified households receive an allowance of SNAP benefits credited to an

13 electronic account. See Irobe v. United States Dep’t of Agric., 890 F.3d 371, 375 14 (1st Cir. 2018). SNAP benefits may only be redeemed for eligible food items. See 7 15 C.F.R. § 274.7(a) (“Program benefits may be used only . . . to purchase eligible 16 food for the household.”); 7 C.F.R. § 271.2 (defining eligible food).

17 Retailers must apply and be authorized by the federal government to accept 18 SNAP benefits. 7 C.F.R. § 278.1(a). At an authorized SNAP retailer, customers 19

20 1 Citations to the Administrative Record (AR), ECF Nos. 13, 14 & 15, are to the provided page number to avoid confusion. 1 redeem their benefits through a process similar to using a credit or debit card. See 2 Irobe, 890 F.3d at 375. The retailer first calculates the total amount due for the

3 customer’s purchase of eligible food items and processes the transaction through 4 an electronic terminal, after which the purchase is debited from the customer’s 5 account, and the retailer is reimbursed by the government. Id.

6 The applicable regulations prohibit “trafficking” SNAP benefits. 7 C.F.R. 7 § 278.6(e)(l)(i); 7 U.S.C. § 2021(b)(3)(B). Trafficking includes, among other 8 things, “buying, selling, stealing, or otherwise effecting an exchange of SNAP 9 benefits . . . for cash or consideration other than eligible food.” 7 C.F.R. § 271.2.

10 The presumptively mandatory penalty for trafficking is permanent disqualification 11 from the SNAP program. 7 C.F.R. § 278.6(e)(l)(i) (“[FNS] shall . . . [d]isqualify a 12 firm permanently if . . . [p]ersonnel of the firm have trafficked as defined in [7

13 C.F.R.] § 271.2”); 7 U.S.C. § 2021(b)(3)(B). However, a retailer found to have 14 engaged in trafficking may be spared disqualification—and instead assessed a 15 monetary penalty—if it “had an effective policy and program in effect to prevent” 16 program violations and provides evidence that the retailer’s ownership was

17 unaware of the violations and did not approve, benefit from, or take part in them. 18 7 U.S.C. § 2021(b)(3)(B); 7 C.F.R. § 278.6. 19 B. The Investigation

20 In 2017, Food and Nutrition Services (“FNS”)—the division within USDA 1 tasked with overseeing the SNAP program—detected “patterns of unusual, 2 irregular, and inexplicable” SNAP transaction activity at the Market. AR 88–97.

3 FNS began an investigation and sent an inspector to visit the Market in April 2018. 4 AR 72. The inspector observed that the store had only two cash registers, each with 5 a terminal capable of processing SNAP transactions, no shopping carts, and only

6 five shopping baskets for customer use. Id. According to the inspector, the most 7 expensive SNAP-eligible item for sale was a can of coffee sold for $13.99. Id. 8 FNS also reviewed and analyzed the Market’s SNAP transaction data for 9 evidence of irregularities. FNS identified a total of 309 transactions with hallmarks

10 of fraud, including eleven sets of multiple SNAP transactions from the same 11 account within a twenty-four-hour period. See AR 91–97. FNS also noted the 12 Market processed significantly more SNAP transactions than nearby comparable

13 retailers and that its SNAP transactions carried higher dollar volumes than those 14 comparable retailers. AR 80–81. Finally, FNS studied the account activity of five 15 households, observing that while each shopped at larger retailers, each also 16 redeemed SNAP benefits at the Market in a suspicious manner. AR 82–86.

17 On May 15, 2018, FNS sent the Market a “charge letter” formally notifying 18 it of the trafficking charge and including a list of the suspicious transactions. 19 AR 88–90. The letter invited Plaintiffs to respond to the allegations, as well as to

20 submit evidence that they maintained a program to ensure compliance with the 1 SNAP program’s regulations. AR 88–89. 2 Plaintiffs responded, denying that the Market processed any fraudulent

3 transactions, but not providing any evidence of a compliance program. AR 100. 4 Plaintiffs explained the Market operated as a “neighborhood market in a low 5 income area of town,” and thus acted more like a grocery store than a convenience

6 store, explaining the suspiciously frequent and large transactions. Id. Specifically, 7 Plaintiffs explained the Market frequently sold twenty-five-pound bags of 8 Ethiopian teff flour for $45.00 per bag, and that customers occasionally bought 9 more than one bag at a time. Id. Plaintiffs attached photographs of the store and

10 invoices from suppliers to substantiate their representations. See AR 101–780. 11 After evaluating Plaintiffs’ response, FNS determined the charge of 12 trafficking had been substantiated, and recommended the Market be permanently

13 disqualified from the SNAP program. AR 798–99.

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