## Facts

- Robin Alexander applied for federal food stamp benefits for her household, which included Scott Bannister.
- Bannister owned a truck used for transportation with a fair market value of $6,625.
- Under 7 U.S.C. § 2014(g)(2), the countable vehicle resource was the amount by which the truck’s fair market value exceeded $4,500 ($2,125).
- The household resource limit was $2,000, so the application was denied based on the countable $2,125 vehicle amount.
- The truck was subject to an $8,300 lien, and Alexander argued the truck should be excluded as an “inaccessible resource” because it could not practically be converted to cash.
- The district court ruled for Alexander, concluding the encumbered truck should be treated as an inaccessible resource and excluded from the resource calculation.
- After the district court decision, the Secretary of Agriculture issued a regulation stating that a vehicle cannot be treated as an “inaccessible resource” for food stamp eligibility.
- The Secretary appealed.

## Issues

1. Whether a vehicle subject to a lien exceeding its value may be excluded from countable resources as an “inaccessible resource” under the USDA’s food stamp regulations.
2. Whether the Secretary’s regulation categorically barring vehicles from the “inaccessible resource” exception is a permissible interpretation of the Food Stamp Act and implementing regulations.

## Decision

- The Ninth Circuit reversed the district court.
- The court upheld the Secretary’s regulation and the denial of benefits.
- The court held that vehicles used for transportation are valued under the statute’s specific formula (fair market value minus $4,500), and liens do not change that method.
- The court held the agency could reasonably treat the vehicle valuation rule as exclusive and categorically exclude vehicles from the “inaccessible resource” exception.

## Legal Principles

- When Congress provides a specific eligibility and valuation rule (here, the vehicle rule in 7 U.S.C. § 2014(g)(2)), an agency may apply that rule according to its terms rather than importing general exceptions that would alter the statutory method.
- For food stamp eligibility, a vehicle used for transportation may be counted as a resource to the extent its fair market value exceeds the statutory threshold, without reducing that value by outstanding liens.
- An agency may, by regulation, reasonably clarify that a statutory category governed by a specific valuation provision (vehicles) is not subject to a more general regulatory exclusion (inaccessible resources).
- Under deferential review of agency interpretations, a categorical rule that promotes uniform administration and avoids case-by-case lien/equity inquiries may be upheld if consistent with statutory text and structure.

## Conclusion

The Ninth Circuit held that the USDA could count a household vehicle as a resource based on fair market value above the statutory amount, even if the vehicle was heavily encumbered by a lien, and could validly bar vehicles from being treated as “inaccessible resources,” thereby sustaining the denial of benefits.


Alexander v. Glickman, 139 F.3d 733 (9th Cir. 1998)