Citation. United States Dep’t of Agric. v. Moreno, 413 U.S. 528, 93 S. Ct. 2821, 37 L. Ed. 2d 782, 1973 U.S. LEXIS 33 (U.S. June 25, 1973)
Brief Fact Summary. An amendment to the Food Stamp Act prevented households made up of unrelated individuals from participating in the program. A class action suit was brought, and the District Court found a Due Process violation.
Synopsis of Rule of Law. The amendment was not rationally related to a legitimate governmental interest, therefore it violated the Due Process Clause.
The Food Stamp Act of 1964 (Act) was established to alleviate hunger and malnutrition among the more needy segments of society. Eligibility was determined on a household rather than individual basis. The household pays for stamps to provide an adequate diet at a reduced rate based upon its size and cumulative income. The Government redeems the stamps at face value from stores, thereby paying the difference. The Act initially defined household as group of related or non-related individuals, who are not residents of an institution or boarding house, but living as one economic unit sharing common cooking facilities for whom food is customarily purchased in common. In 1971 Congress redefined the term household to include only related individuals. The Secretary of Agriculture subsequently promulgated regulations rendering households whose members are not all related ineligible. Appellees consist of several groups of individuals who allege that they have been excluded solely
because the persons in each group are not all related to each other. The appellees instituted a class action seeking declaratory and injunctive relief against the enforcement of the amendment to the Act and its implementing regulations. They contend, and the District Court held, that the provision creates an irrational classification in violation of the equal protection component of the Due Process Clause of the Fifth Amendment. Issue.
Did the District Court err in finding the Act’s amendment that households be related unconstitutional?