United States Department of Agriculture v. Moreno

Brief Fact Summary. The Appellee, Moreno (Appellee), was receiving food stamps from the Appellant, the United States Department of Agriculture (Appellant). In 1971, the Appellant changed the definition of household and Appellee lost all program assistance.

Synopsis of Rule of Law. Discrimination against a politically unpopular group is not a constitutionally permissible government interest. This will fail the rational basis test.

Facts. In 1964 the food stamp program was established. It provided assistance to all households below a certain income level. A household originally was defined as “a group of related or unrelated individuals, who are not residents of an institution or boarding house.” In 1971, the Appellant changed the definition of household to include only those groups of related persons living together.
The Appellee was a 56-year old diabetic who lived with a single mother of 3 small children. Prior to the change, she and the mother received food stamp assistance. But, now her food stamps have been discontinued and the family will loose its ration if it continues to allow the Appellee to live with them.

Issue. Does this classification of “household” violate the Equal Protection Clause of the United States Constitution (Constitution)?

Held. Yes. This classification simply does not operate as to rationally prevent the prevention of fraud. The Food Stamp Act has complete sections devoted to such purpose.

Dissent. This change is rationally related to the prevention of fraud caused by unrelated groups pooling their resources. The fact that there might be unintended consequences does not make the change unconstitutional.

Discussion. The majority recognizes that the intent of this amendment was to discriminate against hippie communes. The Congress may not pass bills designed to purposely harm a politically unpopular group regardless of the reason. This is an exception to the rational basis low level of scrutiny seen in previous cases.