Introduction
Pennsylvania Sues USDA: In June 2025, the Commonwealth of Pennsylvania filed a federal lawsuit against the U.S. Department of Agriculture (USDA), claiming that the abrupt termination of its $13 million Local Food Purchasing Assistance (LFPA) Program agreement violated federal law and harmed the state’s food supply infrastructure. The LFPA Program, launched as a pandemic relief initiative, was intended to strengthen local agricultural supply chains while addressing food insecurity. According to Governor Josh Shapiro, the USDA’s termination of the agreement cut vital support for 189 local farms and left thousands of vulnerable families without access to nutritious food.
Pennsylvania contends that the USDA’s action lacked transparency and failed to comply with established administrative procedures. The state argues that the termination was executed without cause, notice, or the opportunity to respond. The lawsuit raises important constitutional and legal questions regarding the obligations of federal agencies under grant agreements, especially when the programs serve public welfare.
“When federal agencies enter into binding agreements with states, they must honor the terms or provide clear, lawful justifications for any changes,” said Professor Emily Rothstein, a constitutional law expert at the University of Pennsylvania. “Unilateral terminations without process can undermine both legal precedent and public trust.”
At the heart of the dispute is a broader tension between state sovereignty and federal oversight, particularly in matters related to food security, emergency funding, and economic resilience. Pennsylvania’s legal claim not only highlights this friction but also sets the stage for a critical judicial review of agency accountability. If successful, the lawsuit could influence how future federal-state agreements are structured and enforced, particularly in times of crisis or shifting political priorities.
Legal and Historical Background
The Local Food Purchasing Assistance (LFPA) Program was introduced under the authority of the American Rescue Plan Act of 2021 (ARPA), which allocated funds to bolster food security and supply chain resilience during and after the COVID-19 pandemic. Under this program, states received federal grants to purchase food from local producers for distribution through schools, food banks, and childcare centers. The LFPA’s twin goals were to stabilize local agriculture and provide fresh, nutritious food to underserved populations.
Under the Code of Federal Regulations, specifically 2 CFR § 200.340, federal agencies may terminate grant agreements only when they fail to effectuate program goals or when statutory priorities change. However, these terminations must comply with the terms of the agreement and with the Administrative Procedure Act (APA), 5 U.S.C. § 706, which bars agency actions that are arbitrary, capricious, or not in accordance with the law.
Pennsylvania asserts that the USDA’s termination violates both these statutes. Legal scholars argue that the USDA’s lack of explanation, absence of a formal notice, and failure to engage the state before termination run counter to administrative norms.
“Agencies must follow a predictable legal process before revoking grants,” stated legal historian Dr. Marcus Kline of Yale Law School. “The USDA appears to have bypassed that framework, exposing itself to significant judicial scrutiny.”
Historically, courts have invalidated similar federal agency actions. In Motor Vehicle Mfrs. Ass’n v. State Farm, 463 U.S. 29 (1983), the Supreme Court held that agencies must provide rational connections between facts found and choices made. Similarly, in FCC v. Fox Television Stations, 556 U.S. 502 (2009), the Court emphasized that sudden policy reversals require detailed justification. Pennsylvania’s claim leans heavily on these precedents.
The federal-state dynamic has also been contentious in areas involving emergency response, healthcare, and education. The USDA’s move has now sparked new debates on the role and reach of federal agencies during the transition from emergency pandemic governance to post-crisis policymaking.
Case Status and Legal Proceedings
The Commonwealth of Pennsylvania filed its lawsuit in the U.S. District Court for the Middle District of Pennsylvania. The complaint alleges that the USDA acted arbitrarily by terminating the LFPA agreement without cause, prior notice, or an opportunity for the state to contest the decision. The state’s legal team has cited violations of both the APA and the terms outlined in the original federal grant agreement.
The USDA, for its part, has issued only limited public statements, citing ongoing litigation. However, internal memos and correspondence preceding the termination suggest that the USDA viewed the LFPA as a temporary emergency measure whose goals were no longer aligned with the agency’s post-pandemic priorities.
“Administrative law requires consistency, reason-giving, and fair notice,” said administrative law professor Cynthia Alvarez of Georgetown Law. “Sudden reversals that ignore established procedures are legally vulnerable, particularly when they impact public welfare.”
The court will evaluate whether the USDA’s rationale meets the judicial standards set under the APA and whether the agency violated the terms of the LFPA grant. If the court finds the USDA’s action to be arbitrary or in violation of procedure, it could order the reinstatement of the grant or other remedies.
The case is currently in its preliminary stages. Pennsylvania has requested an expedited hearing given the immediate impact on food distribution systems across the state. Legal observers anticipate that the case could set a critical precedent for the limits of federal discretion in managing and terminating state partnerships funded through federal grants.
Viewpoints and Commentary
Progressive / Liberal Perspectives
Progressive organizations and Democratic lawmakers have widely supported Pennsylvania’s decision to challenge the USDA. They argue that the LFPA was an effective and essential initiative that should have been preserved or phased out gradually with sufficient notice. These groups emphasize the social justice implications of terminating food assistance programs without alternatives.
“This isn’t just about contracts. It’s about people being able to eat and farmers being able to survive,” said U.S. Representative Madeleine Dean. “We cannot allow bureaucratic maneuvers to disrupt programs that put food on the table.”
Civil rights groups argue that the termination disproportionately affects marginalized communities, including low-income families, communities of color, and rural populations that rely heavily on food banks. These critics see the USDA’s decision as undermining the Biden administration’s broader goals of equity and inclusion.
Policy think tanks like the Center for American Progress have also weighed in. “Food insecurity is not a temporary issue,” said CAP analyst Joshua Miller. “Cutting programs like LFPA under the guise of shifting priorities disregards the structural inequities in our food systems.”
Additionally, some progressives view the USDA’s action as a concerning rollback of pandemic-era policies that had shown measurable benefits. They fear this could signal a broader trend of deprioritizing public assistance programs in favor of austerity.
Conservative / Right-Leaning Perspectives
Conservative voices have generally defended the USDA’s authority to reassess and reallocate resources based on evolving national needs. Many argue that the LFPA was an emergency program that outlived its original purpose and that continued funding is no longer justified under current budgetary constraints.
“The USDA has a responsibility to manage taxpayer dollars efficiently,” said Senator Pat Toomey, a Republican from Pennsylvania. “If a program is no longer meeting its objectives or has become redundant, it’s entirely appropriate for the agency to end it.”
Right-leaning think tanks such as the Heritage Foundation echo these sentiments. “Temporary programs should not become permanent entitlements,” noted Heritage senior fellow Mark Jamison. “States must adapt and develop their own strategies without expecting indefinite federal support.”
Some conservatives also argue that the lawsuit represents an overreach by the state and a reluctance to accept fiscal realities. They contend that litigation will only prolong dependency on federal funds and delay necessary policy transitions.
Legal analysts from the Federalist Society have pointed to the importance of maintaining executive discretion. “Agency decisions, if made within statutory bounds, should not be second-guessed by courts,” said legal commentator Rachel Chen. “Judicial overreach into agency discretion could undermine governance flexibility.”
Comparable or Historical Cases
Pennsylvania’s case against the USDA resembles several high-profile federal-state legal battles over administrative decision-making and grant termination. One key precedent is Massachusetts v. EPA, 549 U.S. 497 (2007), where the Supreme Court ruled that states have standing to sue federal agencies when their actions—or inactions—cause demonstrable harm.
“Massachusetts v. EPA set the groundwork for state-led challenges to federal regulatory inertia or reversal,” said constitutional law professor Ellen Wexler of Stanford University. “Pennsylvania’s lawsuit continues that tradition by asserting its right to challenge arbitrary agency behavior.”
Another relevant case is Department of Homeland Security v. Regents of the University of California, 591 U.S. ___ (2020), which involved the Trump administration’s attempt to end the DACA program. The Supreme Court ruled that the administration failed to follow proper administrative procedures, thus rendering the action unlawful.
“The DACA case reaffirmed the need for procedural regularity,” said legal analyst Thomas Ngu of NYU Law. “Agencies cannot simply act on impulse; they must justify policy shifts through data, process, and documentation.”
Additionally, Kingdomware Technologies, Inc. v. United States, 579 U.S. 162 (2016), dealt with federal procurement obligations and demonstrated how federal contract decisions can have ripple effects on local economies. Each of these cases underscores the judiciary’s role in checking administrative power, especially when federal decisions disrupt local systems or violate statutory norms.
Policy Implications and Forecasting
The legal outcome of Pennsylvania’s case could significantly influence federal grant policy, agency discretion, and state reliance on federally funded programs. If the court rules in favor of Pennsylvania, it would reinforce procedural safeguards and limit agencies’ ability to unilaterally terminate agreements without stakeholder engagement.
“This lawsuit could shape how grant agreements are structured moving forward,” noted Brookings Institution policy expert Linda Matthis. “States may seek stronger termination clauses and clearer dispute resolution mechanisms in future federal contracts.”
Alternatively, a decision favoring the USDA could embolden federal agencies to revise or rescind temporary programs without fear of judicial intervention. This might prompt states to develop contingency plans and reduce dependence on fluctuating federal policies.
Policy analysts also suggest that the case could prompt Congress to revisit grant governance frameworks. “We may see legislative efforts to clarify agency powers and establish baseline procedural requirements,” said Brennan Center legal fellow Jacob Lin.
Moreover, the lawsuit draws attention to the fragility of the nation’s food systems. A lapse in program funding, even temporary, can disrupt supply chains, hurt farmers, and increase hunger. Long-term planning for food resilience may become a greater policy priority, especially in light of climate risks and economic instability.
Conclusion
The Commonwealth of Pennsylvania’s lawsuit against the USDA highlights enduring tensions between federal authority and state sovereignty, particularly in the realm of public assistance and emergency response. At its core, the case challenges the boundaries of administrative discretion and underscores the need for procedural fidelity in governance.
While progressive voices emphasize equity, food justice, and procedural transparency, conservative perspectives prioritize fiscal responsibility, agency flexibility, and statutory limits. The resulting legal analysis will likely blend these competing imperatives, aiming to delineate a principled approach to federal-state agreements.
“This case isn’t just about food aid,” said legal theorist Professor James Harrow of Columbia Law. “It’s about the foundational trust in how our administrative state functions. The implications extend far beyond one grant program.”
The court’s decision will not only resolve a pressing dispute but also shape future interactions between states and federal agencies. Policymakers, legal experts, and public administrators alike will be watching closely for a verdict that clarifies the legal responsibilities embedded within public governance.
For Further Reading
- Pa. sues USDA over canceled $13M food aid funding
- Pennsylvania sues USDA over cutting funding to $1 billion food aid program for states
- Shapiro Administration Sues USDA Over Terminated $13M Local Food Program
- Pennsylvania sues USDA over $13M program cut
- Shapiro sues USDA over food assistance cuts, Pennsylvania food system in crisis
