U.S. Dept. of Agriculture v. Moreno
413 U.S. 528 (1973)
- Under the Food Stamp Act, the poor would receive credits to buy food.
The eligibility was determined on the basis of overall 'household' income,
not individual income.
- When the law was passed, §3(e) defined a 'household' to include unrelated,
unmarried people living together, as long as they shared household
- A few years later, Congress
modified the definition to only include related and married people as a
- Legislative history shows
that Congress modified §3(e) to
stop "hippies" and "hippie communes" from being
about to take advantage of the program.
- Moreno et. al. sued, claiming
that the change was an unconstitutional violation of the Equal
Protection Clause of the 14th
- The change created two
classes of people, those related to their roommates, and those who
weren't. Those who weren't related were at a disadvantage.
- The US Supreme Court found the
change to be unconstitutional.
- The US Supreme Court found
that that to withstand judicial scrutiny on equal protection grounds, a law must bear a rational relation
to some legitimate end.
- That's the rational
basis test, which is the lowest
level of judicial scrutiny.
- In this case, the Court
found that the classification was clearly irrelevant to the stated
purposes of the Food Stamp Act
and not rationally furthering any other legitimate governmental interest.
- The purpose of the Food
Stamp Act was to stop people from
going hungry, and there was no basis for not allowing unrelated people
to take advantage of the program.
- In general, the courts rarely
overturn a law because it can't meet the rational basis test. The bar is usually pretty low.