U.S. Department of Agriculture v. Moreno

SCOTUS - 1973

Facts

• Section 3(e) of the Food Stamp Act of 1964 (as amended in 1971) excludes from participation in the food stamp program any household containing an individual who is unrelated to any other member of the household.
• Ps brought suit because they have been excluded from the program because of this amendment as a violation of the Equal Protection Clause.

Procedural History

• Lower court held the law unconstitutional.
• SCOTUS affirmed, law unconstitutional.

Issues

• Is Section 3(e) of the Food Stamp Act unconstitutional as a violation of the Equal Protection Clause?

Holding/Rule

• Section 3(e) of the Food Stamp Act is unconstitutional as a violation of the Equal Protection Clause because the means used are not rationally related to the ends sought.

Reasoning

• The challenged statutory classification is clearly irrelevant to the purposes of the Act.

• The legislative history shows that the amendment was intended to prevent hippie communes from participating in the food stamp program.
• A desire to hurt a politically undesirable group cannot constitute a legitimate gov't interest.
• A purpose to discriminate against hippies cannot, of itself, justify the amendment.

• Gov't contends that Congress may have rationally thought…
• That households with one or more unrelated members are more likely than fully related households to contain individuals who abuse the program by fraudulently failing to report sources of income or by voluntarily remaining poor.
• That such households are relatively unstable, thereby increasing the difficulty of detecting such abuses.

• Even if the Court accepts these rationales, the amendment still fails because is not a rational effort to deal with these concerns.
• The Act itself contains provisions aimed specifically of the problems of fraud and of the voluntarily poor.

• In practical operation, the amendment excludes from participation, not those people who are likely to abuse the program, but only those persons who are so desperately in need of aid that they cannot even afford to alter their living arrangements so as to retain their eligibility.

• The classification is wholly without any rational basis.

Dissent

•  Rehnquist
• This is clearly not the rational basis test.
• Congress attacked this problem with a rather blunt instrument and it is possible that the Act will not achieve its intended effect.
• However, questions like this are for Congress, not the courts.
• Court's role is limited to determining whether there is any rational basis on which Congress could decide that public funds made available under the food stamp program should not go to a household containing an individual who is unrelated to any other member of the household.
• This classification could rationally deny food stamps to members of households which have been formed solely for the purpose of taking advantage of the program.
• This was a permissible congressional decision consistent with the underlying policy of the Act.
• The fact that the limitation will have unfortunate and perhaps unintended consequences beyond this does not make it unconstitutional.

Notes

•  None.