Pimentel v. Dreyfus

The district court abused its discretion in granting a preliminary injunction enjoining the State of Washington from terminating a state-funded food assistance program for legal immigrants not qualifying for the federal food assistance program, because plaintiffs failed to show they were likely to succeed on the merits of their due process and equal protection claims.

A group of legal immigrants, represented by Monica Navarro Pimentel, filed a class action suit alleging violations of the Due Process Clause and the Equal Protection Clause of the Fourteenth Amendment following Washington State’s termination of a food assistance program (“FAP”) for aliens not qualifying for the federal food assistance program. The district court granted a preliminary injunction and enjoined Washington from terminating the FAP or decreasing benefits under it. In so doing, the district court found that the class was likely to succeed on the merits of its claims, because members would “suffer irreparable injury” and the “balance of hardships” tipped in their favor over Washington’s budgetary concerns. The Ninth Circuit ruled that the district court abused its discretion by finding that the class members were likely to succeed on the merits of their equal protection and due process claims. The Court held that the equal protection violation claim fails because Pimentel did not indicate other similarly situated individuals receiving different treatment in order to show alienage discrimination. The Court also ruled that Pimentel’s procedural due process claim, alleging insufficient notice of termination of her FAP benefits, would also fail on the merits because she failed to show a property interest in the FAP benefits. The Court REVERSED and VACATED the order granting preliminary injunction and REMANDED for further proceedings.