Hallak

I. BACKGROUND

24 A. Statutory and Regulatory Framework 25 The Supplemental Nutrition Assistance Program (“SNAP”), which is administered 26 by the Food and Nutrition Service (“FNS”), offers food benefits to qualifying individuals 27 and families with financial hardships. See 7 U.S.C. § 2011 et seq.; see also Market v. United 28 States, No. 19–cv–00073, 2020 WL 4043819, at *1 (E.D. Wash. July 17, 2020). “SNAP operates similarly to a debit card, in which benefits are transferred to participants through an Electronic Benefits Transfer (“EBT”) card. Participants may then spend their SNAP benefits by purchasing eligible items sold by approved SNAP retailers.” Rith v. United States, No. 2:19–CV–01582–BJR, 2020 WL 7398750, at *1 (W.D. Wash. Dec. 17, 2020) (citing 7 U.S.C. § 2018 and 7 C.F.R. § 278.1). The applicable regulations prohibit “trafficking” SNAP benefits. C.F.R. § 278.6(e)(1)(i); see also 7 U.S.C. § 2021(b)(3)(B). Trafficking is defined as the “buying, selling, stealing, or otherwise effecting an exchange of SNAP benefits . . . for cash or consideration other than eligible food . . . .” 7 C.F.R. § 271.2. The presumptively…