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.
Under traditional equal protection analysis, a legislative classification must be sustained if the classification itself is rationally related to a legitimate governmental interest.View Full Point of Law
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.