Federal Court Rules Missouri SNAP System Violates ADA and Federal Law Over Call Barriers and Inaccessibility

On May 9, 2024, the United States District Court for the Western District of Missouri granted summary judgment in favor of low-income applicants and advocacy non-profit Empower Missouri against the Acting Director of the Missouri Department of Social Services (DSS). The court concluded that Missouri’s administration of the Supplemental Nutrition Assistance Program (SNAP) violated the federal SNAP Act, the Due Process Clause of the U.S. Constitution, and Title II of the Americans with Disabilities Act (ADA).

Unreachable Call Centers and Automatic Denials

Under federal law and an on-demand waiver from the USDA Food and Nutrition Service (FNS), DSS is permitted to conduct eligibility interviews without scheduling specific times, provided applicants are given meaningful opportunities to interview within 30 days. However, the court found the state’s telephone-based interview system structurally broken.

DSS transitioned to a cloud-based call center system that capped queues, resulting in massive call deflection. In July 2023, the average queue wait time exceeded 50 minutes, and 64,053 calls were deflected from the interview queue (Tier 3). Up to 32 percent of callers who reached the interview queue hung up before speaking to staff. During the first half of 2023, the call center routinely deflected incoming callers as early as 2:00 p.m., even though it operated until 6:00 p.m. In 2023, nearly 60,000 applications were denied solely for failing to complete an interview, representing up to 50 percent of all denials in certain months. The court held that automatically denying benefits under these conditions deprived eligible residents of their property interests in violation of procedural due process.

Systemic Failure to Accommodate Disabilities

The court determined that DSS failed to provide meaningful access to disabled individuals as required by Title II of the ADA. Specific findings included:

• Lack of Accommodation Channels: The agency’s interactive voice response (IVR) phone system provided no option for applicants with disabilities to request accommodations. Notices mailed to applicants lacked guidance on requesting auxiliary aids or lodging ADA complaints with the state.
• Deficient Tracking and Guidelines: DSS lacked written standards, criteria, timelines, or an internal appeal process for reasonable accommodation requests. The agency did not track accommodation requests in its case management systems, nor did granted accommodations persist across recertification cycles.
• Inadequate Staff Training: Out of 129 training slides given to DSS staff, only three mentioned participant ADA accommodations, and none explained how to handle accommodation needs over the phone or affirmatively identify disabled applicants requiring aid.
• Physical Office Shortcomings: Physical Resource Centers often had minimal staffing (19 had only one worker and 60 had two), leading to frequent unscheduled closures, inaccurate operating hours on the website, and refusals by on-site staff to conduct required interviews.

Named plaintiffs included individuals with severe health conditions—such as throat cancer, COPD, and epilepsy—who were denied SNAP benefits when call centers dropped their calls, physical offices turned them away, and written requests for help with forms were ignored. The court noted that another visually impaired applicant who used a screen reader repeatedly requested notices in digital formats over four years, but was refused by a supervisor stating the agency did not have to provide them.

Injunction and Reporting Requirements

To remedy these systemic failures, the court ordered:

1. Remediation Proposals: Within 30 days of the May 9 order, plaintiffs must submit a report detailing specific changes needed to make DSS operations lawful and ADA-compliant. DSS must respond within 30 days, after which plaintiffs have 15 days to reply.
2. State Action Plan: Within 90 days, DSS must file a comprehensive plan of action and timeline to reduce wait times, stop improper interview denials, and ensure full ADA compliance.
3. Monthly Monitoring: Beginning June 15, 2024, DSS must submit monthly tracking reports to the court and Missouri legislative leaders detailing call deflection figures, hold times, call drop rates, interview denial percentages, and ADA accommodation requests.