United States Dept. of Agriculture v. Moreno, 413 U.S. 528 (1973)
The government cannot exclude households from receiving food stamps based on whether they include a person who is unrelated to any other member of the household.
Food stamps were withheld under the Food Stamp Act of 1964 from a household that contained a person who was unrelated to any other person in the household. Congress passed this law with the stated objective of raising the nutrition levels of poor people and improving the agricultural economy. However, it also was designed in a way that would prevent hippies and hippie communes from getting the benefits of it, as the legislative history revealed. A group of impoverished individuals who lived in households where not all members were related to one another argued that the law was unconstitutional under the Equal Protection Clause, and the lower courts agreed.Opinions
- William Joseph Brennan, Jr. (Author)
- William Orville Douglas
- Potter Stewart
- Byron Raymond White
- Thurgood Marshall
- Harry Andrew Blackmun
- Lewis Franklin Powell, Jr.
The purposes of the law are not furthered by withholding its benefits from this particular type of household. Even rational basis review, the lowest standard of scrutiny, requires some reasonable connection between the means used by the government and a legitimate purpose. Preventing hippies and their communes from gaining access to food stamps cannot be defined as a legitimate purpose because it consists simply of a desire to harm a politically unpopular group. Nor does creating the exception to people eligible for benefits support the government interest in reducing fraud. The government provided no persuasive evidence that this type of household will be more likely to fraudulently exploit the program's benefits, and other provisions in the law guard against fraud.
- William Hubbs Rehnquist (Author)
- Warren Earl Burger
A rational basis standard of review does not require an analysis of the effects of the classification. Any rational basis should be sufficient to uphold the law, and such a basis may be found here because households may be formed solely to take advantage of the program's benefits. A law is not unconstitutional just because it has some negative or unintended effects.
- William Orville Douglas (Author)
This type of regulation normally would be reviewed (and upheld) under rational basis scrutiny, the lowest standard of review, since it does not relate to a fundamental right or protected group. However, the Court believed that the definition of household was changed to deny assistance to hippie communes, which it did not find to be a permissible justification.
U.S. Supreme CourtUnited States Dept. of Agriculture v. Moreno, 413 U.S. 528 (1973)
United States Department of Agriculture v. Moreno
Argued April 23, 1973
Decided June 25, 1973
413 U.S. 528
Section 3(e) of the Food Stamp Act of 1964, as amended in 1971, generally excludes from participation in the food stamp program any household containing an individual who is unrelated to any other household member. The Secretary of Agriculture issued regulations thereunder rendering ineligible for participation in the program any "household" whose members are not "all related to each other." Congress stated that the purposes of the Act were
"to safeguard the health and wellbeing of the Nation's population and raise levels of nutrition among low income households . . . [and] that increased utilization of food in establishing and maintaining adequate national levels of nutrition will promote the distribution . . . of our agricultural abundance and will strengthen cur agricultural economy. . . ."
The District Court held that the "unrelated person" provision of § 3(e) creates an irrational classification in violation of the equal protection component of the Due Process Clause of the Fifth Amendment.
Held: The legislative classification here involved cannot be sustained, the classification being clearly irrelevant to the stated purposes of the Act and not rationally furthering any other legitimate governmental interest. In practical operation, the Act excludes not those who are "likely to abuse the program," but, rather, only those who so desperately need aid that they cannot even afford to alter their living arrangements so as to retain their eligibility. Pp. 533-538. 345 F. Supp. 310, affirmed.
BRENNAN, J., delivered the opinion of the Court, in which DOUGLAS, STEWART, WHITE, MARSHALL, BLACKMUN, and POWELL, JJ., joined. DOUGLAS J., filed a concurring opinion, post, p. 413 U. S. 538. REHNQUIST, J., filed a dissenting opinion, in which BURGER, C.J., joined, post, p. 413 U. S. 545.