Lyng v. Castillo

Lyng v. Castillo, 477 U.S. 635 (1986), 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. The Supreme Court ruled that the District court erred in using heightened scrutiny to analyze the validity of the household definition.

Earlier, the Supreme Court ruled in Department of Agriculture v. Moreno, 413 U.S. 528, that the Food Stamp Act of 1971 had an unconstitutional definition of household which would reduce or eliminate benefits if an unrelated individual lived in the household.

Background of case

Eligibility for the federal food stamp program is determined on a “household” basis. However, the exact definition of the term "household" fluctuates and may not include all people living on the same property. Those that are not figured into the discussion include distant family members (farther than first cousin) tenants or sub leasers, non-legally related minors and non-married spouses. The plaintiffs argued that these groups or some of them should be included in proposals for eligibility and quantity of aid supplied.

Disputed Phrasing

"Household" means (1) an individual who lives alone or who, while living with others, customarily purchases foods and prepares meals for home consumption separate and apart from the others, or (2) a group of individuals who live together and customarily purchase food and prepare meals together for home consumption; except that parents and children, or siblings, who live together shall be treated as a group of individuals who customarily purchase and prepare meals together for home consumption even if they do not do so, unless one of the parents, or siblings, is an elderly or disabled member."

Majority opinion

Justice Stevens, writing for the Court, ruled that since it was possible for those who were not included within the household to separately petition for the federal food stamp program, they would not be considered in federal food stamp applications.

Eligibility and benefit levels in the federal food stamp program are determined on a "household," rather than an individual, basis. The statutory definition of the term "household," as amended in 1981 and 1982, generally treats parents, children, and siblings who live together as a single household, but does not treat more distant relatives, or groups of unrelated persons who live together, as a single household unless they also customarily purchase food and prepare meals together. Although there are variations in the facts of the four cases that were consolidated in the District Court, they all raise the question whether the statutory distinction between parents, children, and siblings, and all other groups of individuals violates the guarantee of equal treatment in the Due Process Clause of the Fifth Amendment.^[1]

Dissenting opinions

Justices Brennan, White, and Marshall all authored dissenting opinions.

Brennan

"I would affirm on the ground that the challenged classifications violate the Equal Protection Clause because they fail the rational basis test."

White

"For the reasons given in the last three paragraphs of Justice Marshall’s dissenting opinion, the classification at issue in this case is irrational. Accordingly, I dissent."

Marshall

"This case demonstrates yet again the lack of vitality in this Court's recent equal protection jurisprudence. When it moved beyond the rule that merely grouped parents and children, and, in the 1982 amendments, grouped siblings together as well, Congress interfered substantially with the desires of demonstrably separate families to remain separate families. It did so, moreover, while recognizing that distinct families living together often are genuinely separate households, and that the food stamp program should permit separate families that are not related to live together, but maintain separate households. S.Rep. No. 97-504, at 25. Congress nevertheless assumed that related families are less likely to be genuinely separate households than are unrelated families, and failed even to provide related families a chance to rebut the legislative presumption. In view of the importance to the affected families of their family life and their very survival, the Court's extreme deference to this untested assumption is simply inappropriate. I respectfully dissent."

Continued Controversy

Lyng v. Castillo has again been brought up in recent news. The ruling of the court is preventing same-sex couples living in the same residence from applying from to the federal food stamp program together. They are still able to apply and qualify to receive benefits however they are not recognized similarly to heterosexual couples living together.^[2]

See also

• List of United States Supreme Court cases, volume 477
• List of United States Supreme Court cases
• Lists of United States Supreme Court cases by volume
• List of United States Supreme Court cases by the Rehnquist Court

References

• Lupu Ira C. “WHERE RIGHTS BEGIN: THE PROBLEM OF BURDENS ON THE FREE EXERCISE OF RELIGION.” Harvard Law Review MARCH, 1989 102 Harv. L. Rev. 933
• Weber Gerald R. Jr. The Striker Amendment to the Food Stamp Act: Politics Chipping Away at the Union, Family, and Social Welfare Georgia Law Review Spring 1988 22 Ga. L. Rev. 741

External links

• Text of Lying v. Castillo, 477 U.S. 635 (1986) is available from:  Findlaw  Justia