United States Dep't of Agric. v. Moreno

413 U.S. 528, 93 S. Ct. 2821 (1973)

 

RULE:

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.

FACTS:

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 ruled for appellees. The Supreme Court of the United States affirmed.

ISSUE:

Did the “unrelated person” provision of the Food Stamp Act create an irrational classification in violation of the equal protection component of the due process caluse of the Fifth Amendment?

ANSWER:

Yes.

CONCLUSION:

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.

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