Department of Agriculture v. Moreno
Encyclopedia
Department of Agriculture v. Moreno, , was a case before the United States Supreme Court.
Eligibility for participation in the federal food stamp program is based on households rather than individuals, and under 3(e) of the Food Stamp Act
(7 USCS 2012(e)), the term "household" is defined so as to include only those groups whose members are all related to each other. The plaintiffs were members of groups which were needy, but which were denied food stamps because the groups included members who were not all related to each other. For example, one plaintiff, a 56-year-old diabetic woman, lived with, shared common living expenses with, and received medical care from another woman with three children, each woman receiving a small monthly income from public assistance; another plaintiff, an indigent married woman with three children, took in a 20-year-old girl, who was unrelated to them, because they felt that she had emotional problems; and another plaintiff, whose daughter had an acute hearing deficiency and required special instruction in a school for the deaf, decided that in order to make the most of her limited resources, she would share an apartment near the school with another woman, each woman being a recipient of public assistance.
, the plaintiffs sought declaratory and injunctive relief against the enforcement of the unrelated person provision of 3(e).
A three-judge District Court was convened and held that 3(e) violated the due process clause of the Fifth Amendment, because 3(e) created a classification which achieved apparently unintended results and which was neither relevant to the stated purpose of the Act nor justifiable by reference to an independent purpose (345 F Supp 310). The United States District Court for the District of Columbia held that the "related household" limitation of §3 of the Food Stamp Act of 1964
, 7 U.S.C.S. § 2012(e), was invalid as violative of the Due Process Clause of the Fifth Amendment, because it created an irrational classification in violation of the equal protection component of the Due Process Clause.
, the Court affirmed, Brennan
writing for the Court.
He held that the "unrelated person" provision was irrelevant to the stated purpose of the Food Stamp Act, and because it did not operate to rationally further the prevention of fraud so was not rationally related to furthering any legitimate government interest. The classification acted to exclude not only those who were likely to abuse the program, but also those who were in need of the aid but could not afford to alter their living arrangements so as to retain their eligibility.
While the Fifth Amendment contains no equal protection clause, it does forbid discrimination that is so unjustifiable as to be violative of due process.
Under traditional equal protection analysis, a legislative classification must be sustained if the classification itself is rationally related to a legitimate governmental interest. However, the challenged classification, which excludes unrelated households, simply does not operate so as rationally to further the prevention of fraud.
stated that since the unrelated person provision of 3(e) affected people's First Amendment rights of association, the classification could be sustained only on a showing of compelling governmental interests, and that 3(e) was unconstitutional by reason of its invidious discrimination between one class composed of needy people who are all related to each other and another class composed of households which have one or more persons unrelated to the others, but have the same degree of need as those in the first class.
, joined by Chief Justice Burger
, stated that the limitation which Congress enacted in 3(e) could, in the judgment of reasonable men, conceivably deny food stamps to members of households formed solely for the purpose of taking advantage of the food stamp program; that since the food stamp program was not intended to be a subsidy for every individual who desired low cost food, this was a permissible congressional decision consistent with the underlying policy of the Act; and that the fact that the limitation would have unfortunate and perhaps unintended consequences beyond this did not make it unconstitutional.
Facts
Appellees consisted of several groups of individuals who alleged that, although they satisfied the income eligibility requirements for federal food assistance, they were nevertheless excluded from the program solely because the persons in each group were not all related to each other.Eligibility for participation in the federal food stamp program is based on households rather than individuals, and under 3(e) of the Food Stamp Act
Supplemental Nutrition Assistance Program
The United States Supplemental Nutrition Assistance Program , historically and commonly known as the Food Stamp Program, is a federal-assistance program that provides assistance to low- and no-income people and families living in the U.S. Though the program is administered by the U.S. Department of...
(7 USCS 2012(e)), the term "household" is defined so as to include only those groups whose members are all related to each other. The plaintiffs were members of groups which were needy, but which were denied food stamps because the groups included members who were not all related to each other. For example, one plaintiff, a 56-year-old diabetic woman, lived with, shared common living expenses with, and received medical care from another woman with three children, each woman receiving a small monthly income from public assistance; another plaintiff, an indigent married woman with three children, took in a 20-year-old girl, who was unrelated to them, because they felt that she had emotional problems; and another plaintiff, whose daughter had an acute hearing deficiency and required special instruction in a school for the deaf, decided that in order to make the most of her limited resources, she would share an apartment near the school with another woman, each woman being a recipient of public assistance.
Procedural history
In a class action in the United States District Court for the District of ColumbiaUnited States District Court for the District of Columbia
The United States District Court for the District of Columbia is a federal district court. Appeals from the District are taken to the United States Court of Appeals for the District of Columbia Circuit The United States District Court for the District of Columbia (in case citations, D.D.C.) is a...
, the plaintiffs sought declaratory and injunctive relief against the enforcement of the unrelated person provision of 3(e).
A three-judge District Court was convened and held that 3(e) violated the due process clause of the Fifth Amendment, because 3(e) created a classification which achieved apparently unintended results and which was neither relevant to the stated purpose of the Act nor justifiable by reference to an independent purpose (345 F Supp 310). The United States District Court for the District of Columbia held that the "related household" limitation of §3 of the Food Stamp Act of 1964
Food Stamp Act of 1964
The Food Stamp Act of 1964 provided permanent legislative authority to the Food Stamp Program, which had been administratively implemented on a pilot basis in 1962. It was later replaced and completely rewritten and revised by the food stamp provisions of the Food and Agricultural Act of 1977 The...
, 7 U.S.C.S. § 2012(e), was invalid as violative of the Due Process Clause of the Fifth Amendment, because it created an irrational classification in violation of the equal protection component of the Due Process Clause.
Opinion of the court
On certiorariCertiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
, the Court affirmed, Brennan
William J. Brennan, Jr.
William Joseph Brennan, Jr. was an American jurist who served as an Associate Justice of the United States Supreme Court from 1956 to 1990...
writing for the Court.
He held that the "unrelated person" provision was irrelevant to the stated purpose of the Food Stamp Act, and because it did not operate to rationally further the prevention of fraud so was not rationally related to furthering any legitimate government interest. The classification acted to exclude not only those who were likely to abuse the program, but also those who were in need of the aid but could not afford to alter their living arrangements so as to retain their eligibility.
While the Fifth Amendment contains no equal protection clause, it does forbid discrimination that is so unjustifiable as to be violative of due process.
Under traditional equal protection analysis, a legislative classification must be sustained if the classification itself is rationally related to a legitimate governmental interest. However, the challenged classification, which excludes unrelated households, simply does not operate so as rationally to further the prevention of fraud.
Concurrence
Justice DouglasWilliam O. Douglas
William Orville Douglas was an Associate Justice of the United States Supreme Court. With a term lasting 36 years and 209 days, he is the longest-serving justice in the history of the Supreme Court...
stated that since the unrelated person provision of 3(e) affected people's First Amendment rights of association, the classification could be sustained only on a showing of compelling governmental interests, and that 3(e) was unconstitutional by reason of its invidious discrimination between one class composed of needy people who are all related to each other and another class composed of households which have one or more persons unrelated to the others, but have the same degree of need as those in the first class.
Dissent
Justice RehnquistWilliam Rehnquist
William Hubbs Rehnquist was an American lawyer, jurist, and political figure who served as an Associate Justice on the Supreme Court of the United States and later as the 16th Chief Justice of the United States...
, joined by Chief Justice Burger
Warren E. Burger
Warren Earl Burger was the 15th Chief Justice of the United States from 1969 to 1986. Although Burger had conservative leanings, the U.S...
, stated that the limitation which Congress enacted in 3(e) could, in the judgment of reasonable men, conceivably deny food stamps to members of households formed solely for the purpose of taking advantage of the food stamp program; that since the food stamp program was not intended to be a subsidy for every individual who desired low cost food, this was a permissible congressional decision consistent with the underlying policy of the Act; and that the fact that the limitation would have unfortunate and perhaps unintended consequences beyond this did not make it unconstitutional.
See also
- Lyng v. CastilloLyng v. CastilloLyng v. Castillo, 477 U.S. 635 , reversed a lower court's decision that the change in the statutory definition of a household violated the appellee's due process rights. The program rules for food stamps were changed in 1981 and 1982 which changed the definitions of households...
, 477 U.S. 635 (1986) - List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases, volume 413
- List of United States Supreme Court cases by the Burger Court