Lyng v. International Union, United Auto Workers

Brief Fact Summary.

The International Union, United Auto Workers (Plaintiffs) sucessfully challenged a law making striking employees ineligible for food stamps as a violation of its members rights under the First Amendment and Equal Protection Clause. Secretary Lyng, Department of Agriculture (Defendant), appealed.

Synopsis of Rule of Law.

A statute making families of striking employees ineligible for food stamps is constitutional.

Facts.

In 1984, Congress amended the Food Stamp Act, making families of striking employees ineligible for food stamps. Congress anticipated a substantial savings from this change. Plaintiff sued, arguing that the statute violated its members’ associational and expressive rights under the First Amendment and also violated the Equal Protection Clause of the Fifth Amendment. The court of appeals found the statute unconstitutional on all three grounds and Defendant, the Secretary of the Department of Agriculture, sought certiorari.

Issue.

Is a statute making families of striking employees ineligible for food stamps constitutional?

Held.

(White, J.) Yes. A statute making families of striking employees ineligible for food stamps is constitutional. In Lyng v. Castillo, 477 U.S. 635 (1986), this Court determined that a statutory classification did not interfere with family living arrangements and therefore burden a fundamental right. The same rationale applies here. This statute also does not interfere with union members rights to associate as a union because those rights do not include a requirement that the government fund the exercising of that right. For the same reason, the statute does not restrict an employee’s rights to express himself concerning union matters. The Government is not coercing such speech by choosing not to fund it. The statute does not have a substantial impact on any fundamental interest and does not impact a protected class, so the statute must only be found rationally related to a legitimate government interest to survive. The statute seeks to address a concern that the food stamp program was being used to support one side of private labor disputes. Maintaining neutrality in such labor disputes is a legitimate government interest. This Court does not have the discretion in this case to reject Congress’s decisions on what makes up wise economic or social policy.

Dissent.

(Marshall, J.) The statute fails under even the most deferential standard of constitutional review. A striking employee does not always have a job to return to. The record in this case includes evidence that a number of employees were denied food stamps even after their employers had permanently replaced them. This statute also does not treat the two sides of labor disputes equally, since managerial employees who become temporarily unemployed when a strike causes a shutdown of operations remain eligible for food stamps. This statute creates a penalty for striking employees, not neutrality.

Discussion.

The Court looks to two provisions of the statute to demonstrate that the aim of the legislation is to maintain neutrality in private labor disputes. The first preserves food stamp eligibility for any family that was eligible before the strike. The second maintains eligibility for families where a member is not himself a striker, but refuses to work at a company where the employees are on strike. Justice Marshall’s dissent analyzes legislative history to demonstrate that the amendment is the result of a public dislike of strikers.