Lyng v. Automobile Workers
Annotate this Case
485 U.S. 360 (1988)
U.S. Supreme Court
Lyng v. Automobile Workers, 485 U.S. 360 (1988)
Lyng v. International Union, United Automobile, Aerospace &
Agricultural Implement Workers of America
Argued December 7, 1987
Decided March 23, 1988
485 U.S. 360
Under § 109 of the Omnibus Budget Reconciliation Act of 1981 (OBRA), no household may become eligible to participate in the food stamp program while any of its members is on strike, or receive an increase in the allotment of food stamps it is already receiving because the income of the striking member has decreased. Appellee unions and union members brought suit in Federal District Court, contending that § 109 is unconstitutional. The court granted appellees summary judgment and issued a declaratory judgment, holding the statute unconstitutional on the grounds that it interferes with appellees' associational rights and strikers' expressive rights under the First Amendment, and violates the equal protection component of the Due Process Clause of the Fifth Amendment. The Secretary of Agriculture appealed the decision directly to this Court under 28 U.S.C. § 1252.
1. Section 109 does not violate the First Amendment. Pp. 485 U. S. 364-369.
(a) The statute does not infringe the individual appellees' right to associate with their families or the associational rights of the individual appellees and their unions. It does not prohibit individuals from dining together or associating together to conduct a strike, nor in any other way "directly and substantially" interfere with family living arrangements or workers' ability to combine together to assert their lawful rights. Even if isolated instances can be found in which a striking individual may have left the other members of his household in order to increase their allotment of food stamps or left his union for that purpose, in the overwhelming majority of cases, it is "exceedingly unlikely" that § 109 will have any effect at all. Cf. Lyng v. Castillo, 477 U. S. 635. The Constitution does not require the Government to furnish funds to maximize the exercise of the right of association or to minimize any resulting economic hardship. Pp. 485 U. S. 364-368.
(b) The statute does not abridge appellees' right to express themselves about union matters free of coercion by the Government. Rather
than exacting payments from individuals, coercing particular beliefs, or requiring appellees to participate in political activities or support political views with which they disagree, § 109 merely declines to extend additional food stamp assistance to strikers simply because the strike has caused a decline in their income. Abood v. Detroit Bd. of Education, 431 U. S. 209, distinguished. The Constitution does not confer an entitlement to such governmental funds as may be necessary for individuals to realize all the advantages of their right to free expression. P. 485 U. S. 369.
2. Section 109 does not violate the equal protection component of the Due Process Clause of the Fifth Amendment, since it is rationally related to the legitimate governmental objective of avoiding undue favoritism in private labor disputes. Although the statute does work at least some discrimination against strikers and their households, this Court must defer to Congress' view that the disbursement of food stamps to such persons damages the program's public integrity, and thus endangers its legitimate goals. The fact that § 109 is harder on strikers than on "voluntary quitters" does not render it irrational, since the neutrality concern does not arise with respect to the latter persons. Congress' considered efforts to avoid favoritism are evidenced by § 109's provisos preserving prestrike eligibility and eligibility when a household member has refused to accept employment because of a strike or lockout. OBRA was also enacted for the legitimate purpose of protecting the Government's fiscal integrity by cutting expenditures, and, although this objective cannot be pursued by discriminating against individuals or groups, the Constitution does not permit this Court to disturb the judgment of Congress, the body having discretion as to how best to spend money to improve the general welfare, that passing § 109 along with its provisos was preferable to undertaking other budget cuts in the food stamp program. The contention that § 109 irrationally "strikes at the striker through his family" is without merit, since the food stamp program generally operates against the household of an ineligible person, and the fact that the Act determines benefits on a "household" rather than an individual basis is not constitutionally significant. Pp. 485 U. S. 370-374.
648 F.Supp. 1234, reversed.
WHITE, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and STEVENS, O'CONNOR, and SCALIA, JJ., joined. MARSHALL, J., filed a dissenting opinion, in which BRENNAN and BLACKMUN, JJ., joined, post, p. 485 U. S. 374. KENNEDY, J., took no part in the consideration or decision of the case.
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