The "unrelated person" provision of § 3 (e) of the Food Stamp Act of 1964, 7 U.S.C.S. § 2012(e), creates an irrational classification in violation of the equal protection component of the Due Process Clause of the Fifth Amendment. While the Fifth Amendment contains no equal protection clause, it does forbid discrimination that is so unjustifiable as to be violative of due process.
Appellees consisted of several groups of individuals who alleged that, although they satisfied the income eligibility requirements for federal food assistance, they were nevertheless excluded from the program solely because the persons in each group were not all related to each other. The district court held that the "unrelated person" provision of the Food Stamp Act of 1964 created an irrational classification in violation of the equal protection component of the Due Process Clause of the Fifth Amendment. On certiorari, the Court affirmed.
Does the contested provision violate the equal protection clause?
The "unrelated person" provision was irrelevant to the state purpose of the Food Stamp Act and did not operate to rationally further the prevention of fraud. The classification acted to exclude not only those who were likely to abuse the program, but also those who were in need of the aid but could not afford to alter their living arrangements so as to retain their eligibility. Under traditional equal protection analysis, a legislative classification must be sustained if the classification itself is rationally related to a legitimate governmental interest. The 1971 amendment excludes from participation in the food stamp program, not those persons who are "likely to abuse the program" but, rather, only those persons who are so desperately in need of aid that they cannot even afford to alter their living arrangements so as to retain their eligibility. Traditional equal protection analysis does not require that every classification be drawn with precise "mathematical nicety." But the classification here in issue is not only "imprecise," it is wholly without any rational basis.