Home › Case briefs › Constitutional Law

United States Department of Agriculture v. Moreno

Supreme Court of the United States · 1973 · Constitutional Law

Constitutional LawEqual ProtectionFood Stamp ActFifth Amendmentequal protectionFifth Amendmentdue processrational basis

Facts

The Food Stamp Act originally defined a household to include related or non-related individuals living as one economic unit, sharing cooking facilities, and purchasing food in common. In 1971, Congress amended § 3(e) to exclude, with limited exceptions, households containing an individual unrelated to any other member, and the Secretary adopted regulations requiring household members to be related to each other. Appellees were impoverished persons who otherwise met income eligibility requirements but were denied food stamps solely because they lived with unrelated persons while sharing expenses and cooking arrangements. The amendment in practical effect created two classes for food stamp purposes: households whose members were all related and households containing one or more unrelated persons, with the latter denied assistance.

Issue

Whether § 3(e) of the Food Stamp Act, as amended in 1971 to deny food stamp eligibility to otherwise qualified households containing unrelated persons, violates the equal protection component of the Due Process Clause of the Fifth Amendment. More specifically, the question was whether that classification was rationally related to a legitimate governmental interest.

Rule

Under traditional equal protection analysis, a legislative classification must be sustained if it is rationally related to a legitimate governmental interest. But a bare congressional desire to harm a politically unpopular group cannot constitute a legitimate governmental interest, and a classification that is wholly without rational basis violates the equal protection component of the Fifth Amendment.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

Congress creates a federal housing-subsidy program for low-income households in Denver and defines an eligible household as persons who share expenses and meals, but only if every member is related by blood, marriage, or adoption. A committee report states the amendment was intended to keep "drifters and street collectives" from receiving benefits, even though the excluded households otherwise meet all income rules.

If excluded applicants challenge the amendment, how should a court applying the majority's reasoning most likely rule?

Explanation. The majority held that under the equal protection component of the Fifth Amendment, a legislative classification must be rationally related to a legitimate governmental interest. It further held that a bare congressional desire to harm a politically unpopular group is not legitimate. Here, the stated purpose of excluding disliked "drifters and street collectives" parallels the impermissible purpose identified by the Court, so the classification would fail even under traditional rational basis review.