Singh

I.

BACKGROUND

21 Plaintiffs Ajit Singh and Amar Jit Kaur seek judicial review of the United States 22 Department of Agriculture Food and Nutrition Service’s (“FNS”) agency determination 23 disqualifying Plaintiffs from the Supplemental Nutrition Assistance Program (“SNAP”) 24 for accepting SNAP benefits for ineligible nonfood items. The SNAP provides assistance 25 to low-income households in the United States by allowing individuals to use food stamps 26 to purchase food items from participating stores, but prohibits the redemption of coupons 27 28 for ineligible items. (See Def.’s Mot. to Dismiss, ECF No. 3, at 2–3); 7 U.S.C. §§ 2011, 2013(a); 7 C.F.R. § 278.2(f). Plaintiffs are husband and wife who operate a retail store in Imperial County, California. (Compl. ¶¶ 2, 7, 9.) On August 15, 2019, after conducting an investigation of Plaintiffs’ business, FNS charged Plaintiffs with trafficking in SNAP benefits. (Ex. A to Def.’s Mot. to Dismiss, ECF No. 5-1, at 3.) On February 13, 2020, FNS determined Plaintiffs had trafficked in SNAP benefits as charged and permanently disqualified Plaintiffs from SNAP. (Id. at 4.) Plaintiffs appealed,…