USA Market Inc. v. United States

CourtDistrict Court, E.D. Missouri
DecidedAugust 23, 2024
Docket4:23-cv-01166
StatusUnknown

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

Bluebook
USA Market Inc. v. United States, (E.D. Mo. 2024).

Opinion

EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

AMS MARKET, INC. d/b/a ) USA Market, ) ) Plaintiff, ) ) v. ) No. 4:23-CV-1166 HEA ) UNITED STATES OF AMERICA, ) through its agency, the United States ) Department of Agriculture, ) ) Defendant. )

OPINION, MEMORANDUM AND ORDER This matter is before the Court on Plaintiff’s Motion for Stay of the Food and Nutrition Services’ Final Agency Decision pursuant to 7 U.S.C. § 2023(a)(17). (ECF No. 7). Defendant United States of America through its agency, the U.S. Department of Agriculture (“USDA,” the “Government” or “Agency”) opposes the motion and has filed a memorandum in response. Plaintiff did not file a reply memorandum, and the time to do so has expired. For the following reasons, the Court denies Plaintiff’s motion. I. Background Plaintiff AMS Market, Inc. d/b/a USA Market (“USA Market”) operates a store, which it characterizes as a grocery and convenience store, in Ferguson, Missouri. On April 12, 2022, USDA informed USA Market through a charge letter that it was in violation of the Supplemental Nutrition Assistance Program (“SNAP”) Electronic Benefit Transfer (“EBT”) transactions between May and September 2021. The letter asserted that the EBT transactions “establish clear and repetitive patters of unusual, irregular, and inexplicable SNAP active for your type of firm.”

(ECF No. 12, Ex. 1 at 1). The letter also informed USA Market that it was subject to permanent disqualification from SNAP, although it could request a civil monetary penalty in lieu of permanent disqualification. (Id.) USA Market responded to the charge and denied that it had engaged in

trafficking SNAP benefits. According to USA Market, the EBT transactions at issue were legitimate transactions. It argued, among other things, that: (1) USA Market has a kitchen that prepares hot food for customers and, therefore, its per transaction

amounts are higher than “chips and soda” convenience stores; and (2) the Government provided significantly increased SNAP benefits during the COVID-19 pandemic and, therefore, USA Market’s customers had more benefits to spend. (ECF No. 8 at 8). In its response, USA Market provided the Government with a

number of documents including menus, photographs, receipts, invoices, and affidavits to support its assertion that all of its transactions were legitimate sales of eligible food items. USA Market also urged USDA to impose a civil monetary

penalty against it in lieu of a permanent ban. USA Market asserted that it qualified

2 policy and program to prevent violations of the SNAP regulations. In a letter dated November 9, 2022, USDA informed USA Market that it was being permanently disqualified as an authorized retailer in SNAP for trafficking

violations. The letter further stated that USA Market was not eligible for a civil monetary penalty in lieu of the permanent ban, because USA Market had not submitted substantial evidence that there was a compliance policy and program in place prior to the violations. USA Market was prohibited from accepting SNAP

benefits as of November 10, 2022. USA Market appealed this decision and requested an administrative review. Following submission of additional information and documents, the Food and

Nutrition Service Administrative Review Branch issued a Final Agency Decision dated August 21, 2023, that sustained the decision to permanently disqualify USA Market from SNAP. (ECF No. 12, Ex. 1). USA Market filed this action pursuant to 7 U.S.C. § 2023(a)(13) seeking judicial review of the Agency’s decision to

permanently disqualify it from SNAP.1

1Section 2023(a)(13) provides as follows:

If the store, concern, or State agency feels aggrieved by such final determination, it may obtain judicial review thereof by filing a complaint against the United States in the United States court for the district in which it resides or is engaged in business, or, in the case of a retail food store or wholesale food concern, in any court of record of the State having competent jurisdiction, within thirty days after the date of delivery or service of the final notice of determination upon it, requesting

3 administrative action disqualifying it from SNAP pending judicial review. USDA opposes USA Market’s motion. The Government argues Plaintiff is not entitled to a stay, because under the plain language of the statute, as well as under the

regulations issued by USDA, stays are not authorized where a store has been permanently disqualified based on a finding of trafficking. The Government further argues that even if the Court were to take up the issue on the merits, Plaintiff is not entitled to a stay, because USA Market cannot show there is a likelihood that it will

succeed on the merits of its claim, or that it will suffer irreparable harm. The Court will first address whether under 7 U.S.C. § 2023(17) and (18) it is authorized to enter a stay of USDA’s determination that USA Market is permanently

disqualified from SNAP – an issue neither the U.S. Supreme Court nor the Eighth Circuit Court of Appeals has addressed. II. Discussion Congress established SNAP “to safeguard the health and well-being of the

Nation’s population by raising levels of nutrition among low-income households.” 7 U.S.C. § 2011. SNAP provides eligible households with EBT cards that may be used to purchase qualifying food items at authorized retail stores. 7 U.S.C. § 2013;

the court to set aside such determination.

7 U.S.C. § 2023(a)(13)

4 683538, at *1 (D. Md. Mar. 1, 2012). When an individual uses his or her EBT card for a transaction to purchase food, the household’s SNAP account is debited, and the retailer is subsequently reimbursed by the Government. Id.

SNAP households and authorized retailers are subject to a number of statutory provisions and regulations. In order to safeguard the integrity of the program and to prevent abuse, Congress established penalties for retailers that violate SNAP’s statutory provisions and regulations. There is a range of penalties for violations

including civil monetary penalties, suspension, and permanent disqualification. Trafficking in benefits carries the stiffest penalty – permanent disqualification from SNAP.2 7 U.S.C. § 2021(a)(3)(B). In fact, the statute provides that a retailer

engaged in trafficking is subject to a permanent ban on its first offense, unless there is a determination that it had an effective anti-trafficking policy in place, and there is substantial evidence that ownership and management were not aware of and did not approve of or benefit from the trafficking. Id. In this case, USDA made a

2Trafficking is defined as follows:

The buying, selling, stealing, or otherwise effecting an exchange of SNAP benefits issued and accessed via Electronic Benefit Transfer (EBT) cards, card numbers and personal identification numbers (PINs), or by manual voucher and signature, for cash or consideration other than eligible food, either directly, indirectly, in complicity or collusion with others, or acting alone[.]

7 C.F.R. §

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186 F. Supp. 2d 1203 (M.D. Florida, 2001)
Ameira Corp. v. Veneman
169 F. Supp. 2d 432 (M.D. North Carolina, 2001)
Hennepin County v. Federal National Mortgage Ass'n
742 F.3d 818 (Eighth Circuit, 2014)
Dinner Bell Markets, Inc. v. United States
116 F. Supp. 3d 905 (S.D. Indiana, 2015)

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USA Market Inc. v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/usa-market-inc-v-united-states-moed-2024.