## Facts

- Low-income food-stamp recipients in several Florida counties sued the local state attorney and state agency officials who administered the Food Stamp Program.
- In an ongoing food-stamp fraud investigation, the state attorney subpoenaed from the state agency the files of all recipient households receiving at least $125 per month in food stamps.
- The subpoena was not based on any reason to believe any particular recipient had committed fraud.
- After obtaining the files, the prosecutor’s office created household “information sheets” and distributed them to local police to conduct field checks of application information.
- Plaintiffs sought injunctive relief to stop disclosure and use of recipient files absent individualized suspicion of fraud, and also sought damages, alleging violations of the Food Stamp Act and regulations and constitutional rights.

## Issues

1. Whether the Food Stamp Act and 7 C.F.R. § 272.1(c) permit a state agency to disclose food-stamp recipient files to a prosecutor without a showing of individualized suspicion of fraud.
2. Whether the district court abused its discretion in denying a preliminary injunction against the challenged disclosure and investigation practices.

## Decision

- The Fifth Circuit reversed the denial of the preliminary injunction and remanded.
- The court held that the Food Stamp Act reflects a strong congressional intent to keep recipient files confidential.
- The court interpreted 7 C.F.R. § 272.1(c) to require a showing of suspicion of fraud before the state agency may release recipient files to prosecutorial officials.
- Because the district court’s denial rested on an incorrect legal interpretation allowing suspicionless disclosure, it abused its discretion; the plaintiffs’ proposed injunction satisfied the established preliminary-injunction requirements.

## Legal Principles

- Food-stamp recipient information is subject to strong statutory and regulatory confidentiality protections.
- Under 7 C.F.R. § 272.1(c), disclosure to persons “directly connected” with program enforcement is not unlimited; it requires a concrete connection to suspected violations, including suspicion of fraud tied to particular cases.
- A district court abuses its discretion in ruling on preliminary injunctive relief when its decision rests on a misinterpretation of controlling law.
- Statutory and regulatory confidentiality limits can independently support injunctive relief even when constitutional claims are also pleaded but not decided.

## Conclusion

The Fifth Circuit required individualized suspicion of fraud before a state agency may disclose food-stamp recipient files to a prosecutor under the governing confidentiality regulation, and it reversed the denial of a preliminary injunction that would have restrained suspicionless, program-wide file access and field investigations.


Roberts v. Austin, 632 F.2d 1202 (5th Cir. 1980)