Cindy Gonzalez, Defendant Below, Appellant v. the State of Delaware, Plaintiff Below, Appellee.

Summary

The Supreme Court of Delaware held that federal law preempts Delaware's civil fraud claims against a SNAP recipient after the State had already completed an administrative disqualification proceeding based on the same intentional program violations. The federal statute requires a state to proceed either through an administrative hearing or by referring the matter for civil or criminal court action, and the statutory text, amendment history, and implementing regulations establish that these alternatives are exclusive. The court therefore reversed the Superior Court's grant of judgment on the pleadings to the State.