Lyng v. Castillo - 477 U.S. 635 (1986)
U.S. Supreme Court
Lyng v. Castillo, 477 U.S. 635 (1986)
Lyng v. Castillo
Argued April 29, 1986
Decided June 27, 1986
477 U.S. 635
Eligibility and benefit levels in the federal food stamp program are determined on a "household," rather than an individual, basis. The statutory definition of the term "household," as amended in 1981 and 1982, generally treats parents, children, and siblings who live together as a single household, but does not treat more distant relatives, or groups of unrelated persons who live together, as a single household unless they also customarily purchase food and prepare meals together. Appellees are families who generally buy their food and prepare their meals as separate economic units, and who will either lose benefits or have their food stamp allotment decreased as a result of the 1981 and 1982 amendments to the statute. They filed actions that were consolidated in Federal District Court, claiming that the statutory distinction between parents, children, and siblings and all other groups of individuals violates the guarantee of equal treatment in the Due Process Clause of the Fifth Amendment. On cross-motions for summary judgment, the District Court, applying "heightened scrutiny," invalidated the distinction.
Held: The statutory distinction is not unconstitutional. The District Court erred in judging its constitutionality under "heightened scrutiny," since close relatives are not a "suspect" or "quasi-suspect" class. The statutory distinction does not "directly and substantially" interfere with family living arrangements, and thereby burden a fundamental right. Judged under the proper standard of review, Congress had a rational basis for making the distinction, since it could reasonably determine that close relatives sharing a home tend to purchase and prepare meals together, while distant relatives and unrelated individuals might not be so inclined. Pp. 477 U. S. 638-643.
STEVENS, J., delivered the opinion of the Court, in which BURGER, C.J., and BLACKMUN, POWELL, REHNQUIST, and O'CONNOR, JJ., joined. BRENNAN, J., post, p. 477 U. S. 643, WHITE, J., post, p. 477 U. S. 643, and MARSHALL, J., post, p. 477 U. S. 643, filed dissenting opinions.