Background
Brad Brown owned Brothers Market LLC No. 2, a small convenience store in downtown Los Angeles authorized to participate in the Supplemental Nutrition Assistance Program. In early 2022, the Food and Nutrition Service detected suspicious transaction patterns at the store, including unusually large transactions, benefits-depleting purchases, rapid successive transactions, and repeated same-dollar-value transactions. The Agency charged the store with trafficking in SNAP benefits and permanently disqualified it after the store failed to provide a meaningful explanation for the patterns.
The court’s reasoning
The panel reviewed the district court’s grant of summary judgment de novo. The government produced evidence of transaction patterns that, given the store’s small size and limited inventory, supported an inference of SNAP trafficking. The court found that the plaintiffs did not dispute that the transactions occurred but failed to provide evidence that would allow a factfinder to conclude the patterns did not support a trafficking finding. The court rejected the plaintiffs’ affidavits and general theories as insufficient to create a genuine dispute of material fact, noting that the store’s receipts and other evidence did not account for the hundreds of flagged transactions.
Given the overwhelming evidence of SNAP trafficking and Plaintiffs’ lack of a meaningful showing to the contrary, the panel affirmed the district court’s grant of summary judgment for the government.
Brothers Market LLC No. 2 v. United States, 24-6374 (9th Cir. Apr. 8, 2026)
What it means going forward
The decision reinforces that circumstantial evidence of transaction patterns is sufficient to sustain a SNAP trafficking finding at summary judgment, placing a heavy burden on retailers to provide specific, corroborating evidence to rebut such patterns.