United States Department of Agriculture v. Murry
413 U.S. 508, 37 L. Ed. 2d 767, 1973 U.S. LEXIS 32 (1973)
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Rule of Law:
A legislative provision that creates a conclusive and irrebuttable presumption of fact, which is not universally true and operates to deny essential government benefits without an opportunity for an individualized determination of actual need, violates the Due Process Clause of the Fifth Amendment.
Facts:
- Appellee Murry, her two sons, and ten grandchildren lived together on a monthly income of $57.50.
- Appellees Valdez and Broderson were married 18-year-olds with children who received no financial support from their fathers.
- Appellee Lee was deserted by her husband, who provided no support for her or their five children.
- Appellee Schultz was 19, had no income, and was refused any aid by her parents.
- In each case, a person outside the household who was not eligible for food stamps (an ex-husband or parent) claimed one of the household members over age 18 as a tax dependent for the previous year.
- Despite providing little or no actual support, these tax dependency claims made the entire households of the appellees automatically ineligible for food stamps under Section 5(b) of the Food Stamp Act.
- The appellees were denied an opportunity to present evidence that, despite the tax claim, their households were in fact needy and eligible for assistance.
Procedural Posture:
- Appellees, individuals whose households were denied food stamps, brought a class action lawsuit in federal court against the U.S. Department of Agriculture.
- The suit sought to enjoin the enforcement of the 'tax dependency' provision of the Food Stamp Act.
- A three-judge District Court panel heard the case and held that the provision was unconstitutional.
- The District Court granted the injunction sought by the appellees.
- The U.S. Department of Agriculture, the defendant, appealed this decision directly to the Supreme Court of the United States.
- The Supreme Court noted probable jurisdiction to hear the appeal.
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Issue:
Does Section 5(b) of the Food Stamp Act, which makes an entire household ineligible for food stamps if it contains a member over 18 who was claimed as a tax dependent by a non-eligible taxpayer in the prior year, violate the Due Process Clause of the Fifth Amendment?
Opinions:
Majority - Douglas, J.
Yes. The provision violates the Due Process Clause because it rests on an irrebuttable presumption that is often contrary to fact. The statute presumes that because a household member was claimed as a tax dependent in a prior year, the entire household is not currently in need of food assistance. This presumption is irrational because the tax deduction benefits the parent, not the household, and is not a reliable measure of the household's present need. The law denies benefits to destitute households based on this arbitrary classification, sacrificing due process for the sake of administrative convenience, which is impermissible when fundamental needs are at stake.
Concurring - Stewart, J.
Yes. The law's conclusive presumption denies due process. Citing Vlandis v. Kline, the opinion argues that the government cannot deny benefits based on a permanent, irrebuttable presumption when that presumption is not universally true and when reasonable alternative means exist to make the crucial determination of need. The statute's flaw is that it completely terminates benefits for an entire household regardless of whether the dependency claim was fraudulent, the amount of support actually provided, or whether that support was still available, thereby denying individuals the opportunity to prove their present need.
Concurring - Marshall, J.
Yes. The Due Process Clause requires an individualized determination of need in this situation. Where important private interests, such as the ability to purchase food, are affected, and the government's interest in preventing abuse can be achieved through a hearing procedure, a general rule that serves only as a conclusive presumption is unfair. The statute is not reasonably calculated to eliminate only abusers, as it harms entire, genuinely needy households based on the status of a single member. Fairness demands a mechanism for individuals to show that the presumed support does not actually offset their need.
Dissenting - Blackmun, J.
No. The court should vacate and remand for a factual hearing rather than striking down the statute. The statutory term 'claimed as a dependent' should be interpreted to mean 'properly claimed' under the Internal Revenue Code. The appellees in this case were likely claimed improperly, as they received little or no support from the taxpayers. Therefore, the issue is not the unconstitutionality of the Food Stamp Act, but the potentially fraudulent tax filings of third parties. The proper remedy is a hearing to determine the validity of the dependency claims, not the invalidation of the statute.
Dissenting - Rehnquist, J.
No. The statute is a rational exercise of congressional power in the area of social and economic welfare and should be upheld. This case involves a substantive legislative classification, not a procedural due process issue of irrebuttable presumptions. Under the rational basis standard established in cases like Dandridge v. Williams, such classifications need not be perfect, only reasonably related to a legitimate government purpose. Congress's goal was to prevent abuse of the food stamp program by non-needy individuals, like college students supported by wealthy parents. Creating a rule based on tax dependency status is a rational, if imperfect, way to achieve this goal, and the Court should not substitute its policy judgment for that of Congress.
Analysis:
This decision is a high-water mark for the 'irrebuttable presumption' doctrine, which the Court used in the early 1970s to strike down legislative classifications under the guise of procedural due process. It subjected welfare regulations to a higher level of scrutiny than traditional rational basis review by demanding individualized hearings over broad, prophylactic rules designed for administrative efficiency. While seemingly protecting vulnerable individuals, the doctrine was criticized for blurring the lines between procedural and substantive due process. The Court later retreated from this approach, largely adopting the more deferential standard articulated in Justice Rehnquist's dissent for economic and social legislation.
