Department of Agriculture v. Moreno

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Department of Agriculture v. Moreno, 413 U.S. 528 (1973), was a United States Supreme Court case in which the Court invalidated a provision of the Food Stamp Act denying food stamps to households of "unrelated persons." The Court held that this provision was irrelevant to the stated purpose of the statute and violated the Due Process Clause of the Fifth Amendment.

Background

Facts

The case was brought by 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 was based on households rather than individuals. Under Section 3(e) of the Food Stamp Act (7 USC 2012(e)), the term "household" was defined so as to include only those groups whose members are all related to each other. The plaintiffs were members of groups of needy individuals who 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 Columbia, 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.

Opinion of the court

In an opinion by JusticeWilliam J. Brennan, Jr., the Supreme Court affirmed the lower courts' ruling that the statutory classification was invalid.

The Court 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. This doctrine is commonly referred to as "reverse incorporation" as it is essentially the opposite of "incorporation", or the application of parts of the Bill of Rights (otherwise applicable only to the Federal government) to the states via the Fourteenth Amendment.

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 Court held, the challenged classification, which excludes unrelated households, did not rationally further the goal of preventing fraud.

Concurrence

Justice William O. Douglas wrote a concurring opinion. In his view, since the unrelated-person provision of Section 3(e) affected people's First Amendment rights of association, the classification could be sustained only on a showing of compelling governmental interests. In Douglas' view, that standard was not satisfied. In addition, Section 3(e) was unconstitutional because 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 William H. Rehnquist dissented from the Court's decision. In an opinion joined by Chief Justice Warren E. Burger, Rehnquist opined that the limitation which Congress enacted in Section 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. Since the food stamp program was not intended to be a subsidy for every individual who desired low-cost food, in Rehnquist's view, this was a permissible congressional decision consistent with the underlying policy of the Act. The fact that the limitation would have unfortunate and perhaps unintended consequences beyond this did not make it unconstitutional.

See also

• Lyng v. Castillo, 477 U.S. 635 (1986)

References

• Department of Agriculture v. Moreno, 413 U.S. 528 (1973)

External links

• Text of Department of Agriculture v. Moreno, 413 U.S. 528 (1973) is available from:  Findlaw  Justia