CONCLUSION
The primary function of a preliminary injunction “is to preserve the status quo until, upon final hearing, a court may grant full, effective relief.” Missouri, 128 F.4th at 990 (citation omitted). By all accounts, Minnesota has operated its SNAP recertification process in compliance with federal law and with the express blessing of the USDA. The Recertification Letter and Enforcement Letter seek to upend that status quo, and, without any reasoned explanation, demand that Minnesota implement an entirely new process within 30 days. This sort of haphazard decisionmaking is precisely what the APA is intended to prevent and what a preliminary injunction is to remedy. Accordingly, because Minnesota is likely to succeed on at least one of its APA claims, and because all other factors for injunctive relief fall in Minnesota’s favor, the Court grants Minnesota’s motion for a preliminary injunction.
ORDER
For the reasons stated above, Minnesota’s motion (ECF No. 5) is hereby GRANTED, and the USDA is PRELIMINARILY ENJOINED from taking any adverse action against Minnesota based on the Recertification Letter, and PRELIMINARILY ENJOINED from withholding any of Minnesota’s administrative funding for the first quarter of calendar year 2026 as threatened in the Enforcement Letter.
LET JUDGMENT BE ENTERED ACCORDINGLY.
Dated: January 16, 2026
s/Laura M. Provinzino
Laura M. Provinzino
United States District Judge