U.S. Dept. of Agriculture v. Moreno
413 U.S. 528 (1973)
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Rule of Law:
A legislative classification that creates a distinction between groups of people must be rationally related to a legitimate government interest. A bare congressional desire to harm a politically unpopular group cannot constitute a legitimate governmental interest under the equal protection component of the Fifth Amendment's Due Process Clause.
Facts:
- In 1971, Congress amended the Food Stamp Act to define a 'household' as a group of related individuals, thereby excluding households with unrelated members from eligibility.
- Jacinta Moreno, a 56-year-old diabetic, lived with Ermina Sanchez and her three children to share expenses and receive care, as both relied on public assistance.
- Sheilah Hejny and her indigent family took in an unrelated 20-year-old girl who had emotional problems and needed a place to live.
- Victoria Keppler, a mother on public assistance, shared an apartment with an unrelated woman to afford housing near a special school for her deaf daughter.
- Due to the 1971 amendment, Moreno, the Hejny family, and Keppler were either denied food stamps or notified that their benefits would be terminated because their households included an unrelated individual.
Procedural Posture:
- Jacinta Moreno and other individuals in similar situations filed a class-action lawsuit against the U.S. Department of Agriculture in the U.S. District Court for the District of Columbia.
- The plaintiffs sought a declaratory judgment and an injunction to stop the enforcement of the 'unrelated person' provision of the Food Stamp Act.
- A three-judge panel of the District Court found the provision unconstitutional, ruling that it violated the equal protection component of the Fifth Amendment's Due Process Clause.
- The Department of Agriculture (the appellant) appealed this decision directly to the Supreme Court of the United States, which noted probable jurisdiction.
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Issue:
Does the provision of the Food Stamp Act that excludes households containing one or more unrelated individuals from receiving benefits violate the equal protection component of the Fifth Amendment's Due Process Clause?
Opinions:
Majority - Justice Brennan
Yes, the provision violates the equal protection component of the Fifth Amendment's Due Process Clause. A legislative classification must be sustained if it is rationally related to a legitimate governmental interest, but the 'unrelated person' provision fails this test. The classification is irrelevant to the Food Stamp Act's stated purposes of alleviating hunger and strengthening the agricultural economy. The legislative history reveals the amendment's actual purpose was to prevent 'hippies' and 'hippie communes' from receiving food stamps, and a bare desire to harm a politically unpopular group is not a legitimate government interest. Furthermore, the government's asserted justification of preventing fraud is not rationally served by this classification, as the Act already contains specific anti-fraud provisions, and the rule irrationally harms the most desperate households while allowing those it targets to easily circumvent the rule by altering their living arrangements.
Concurring - Justice Douglas
Yes, the provision is unconstitutional. This case implicates the fundamental right of association protected by the First Amendment, as impoverished individuals band together in households for mutual support. Because the law has an impact on this fundamental right, it must be subjected to the 'closest scrutiny' and can only be sustained by a 'compelling' governmental interest, not merely a rational basis. The law penalizes the poor for exercising their associational rights and is not narrowly drawn to address the government's concern about fraud. The invidious discrimination between needy households of related persons and equally needy households containing an unrelated person cannot be justified.
Dissenting - Justice Rehnquist
No, the provision does not violate the Fifth Amendment. The role of the Court is only to determine if there is any rational basis for the law, not to act as a congressional committee debating its wisdom. It is not unreasonable for Congress to conclude that the basic unit it wishes to support with federal funds is a variation of the family, consisting of related individuals. This provides a guarantee that the household exists for a purpose other than to collect food stamps. While the classification may be imprecise and have unintended consequences, it is a permissible legislative decision aimed at preventing fraud, and such policy judgments are for Congress, not the courts, to make.
Analysis:
This decision is a key example of the 'rational basis with bite' standard of review. While purporting to apply the deferential rational basis test, the Court rigorously scrutinized the government's justifications and found the actual legislative purpose—animus toward an unpopular group—to be illegitimate. This holding establishes that even under the lowest tier of scrutiny, a law motivated by a bare desire to harm a politically unpopular group fails to serve a legitimate governmental interest and is therefore unconstitutional. It signals that courts may look beyond post-hoc rationalizations to invalidate laws based on impermissible legislative motives.
