Perrone v. Rollins

The plaintiffs invoked the notice-and-comment requirement by arguing that the administration's direction to restrict SNAP benefits for non-citizens and enforce state waiver options constituted a substantive eligibility change requiring prior rulemaking under the APA, and they relied on Goldberg's guarantee of pre-termination notice and opportunity to be heard before their individual benefits were suspended. However, when the government shutdown ended on November 12, 2025, SNAP funding resumed and the recipients' benefits were restored, rendering the case moot, the concrete injury the plaintiffs sought to remedy had been cured by events independent of the court's review. The voluntary dismissal thus left unresolved whether the administration's approach would have violated the APA or Food and Nutrition Act absent the shutdown's intervention, leaving no precedent on the merits regarding mandatory federal SNAP obligations during appropriations disputes.