explaining that because the “challenged statutory classification . . . is clearly irrelevant to the stated purposes of the Act,” it “must rationally further some legitimate governmental interest other than those specifically stated in the congressional ‘declaration of policy’” in order “to be sustained”
How later courts described this case
- explaining that because the “challenged statutory classification . . . is clearly irrelevant to the stated purposes of the Act,” it “must rationally further some legitimate governmental interest other than those specifically stated in the congressional ‘declaration of policy’” in order “to be sustained”
- finding discrimination aimed at hippies irrational and concluding that, if "the constitutional conception of `equal protection of the laws' means anything, it must at the very least mean that a bare . . . desire to harm a politically unpopular group cannot constitute a legitimate governmental interest"
- explaining that where other safeguards in the Food Stamp Act already existed, the challenged provision, which excluded from eligibility for food stamps those individuals who resided with non-relatives, was not rationally related to a legitimate governmental purpose and instead was arbitrary
- holding that a statutory classification limiting participation in the Food Stamp Act, 7 U.S.C. §§ 2011-2036, to households composed of related individuals could not be sustained by legislative history indicating that the classification was intended to prevent “hippies” from participating
Written by the judges who cited it.
Distinguished
Distinguished by Grocery Manufacturers Ass'n v. Sorrell, 102 F. Supp. 3d 583 (2015)
” Id. Moreno is inapplicable to this case as Plaintiffs are not-a politically unpopular group that has been subjected to purposeful and unconstitutional discrimination in violation of the Equal Protection Clause.
Distinguished by a later decision, 169 F.3d 1342 (1999)
Finally, we reject the plaintiffs' contention that the Supreme Court's decisions in United States Dept. of Agric. v. Moreno, 413 U.S. 528, 93 S.Ct. 2821, 37 L.Ed.2d 782 (1973), and Romer v. Evans, 517 U.S. 620, 116 S.Ct. 1620, 134 L.Ed.2d 855 (1996), somehow compel us to conclude that § 1612 fails rational basis scrutiny.
Distinguished by Madrick v. Shalala, 885 F. Supp. 182 (1995)
” Id., at 533, 93 S.Ct. at 2825. Moreno is inapplicable to Madrick’s complaint as the regulations which Madrick complains of do not pose equal protection problems as the regulations are treating all individuals equally.
The opinion
Mr. Justice Rehnquist,
with whom The Chief Justice concurs, dissenting.
For much the same reasons as those stated in my dissenting opinion in United States Department of Agriculture v. Murry, ante, p. 522, I am unable to agree with the Court’s disposition of this case. Here appellees challenged a provision in the Federal Food Stamp Act, 7 U. S. C. § 2011 et seq., which limited food stamps to related people living in one “household.” The result of this provision is that unrelated persons who live under the same roof and pool their resources may not obtain food stamps even though otherwise eligible.
The Court’s opinion would make a very persuasive congressional committee report arguing against the adoption of the limitation in question. Undoubtedly, Congress attacked the problem with a rather blunt instrument and, just as undoubtedly, persuasive arguments may be made that what we conceive to be its purpose will not be significantly advanced by the enactment of the limitation. But questions such as this are for Congress, rather than for this Court; our role is limited to the *546 determination of whether there is any rational basis on which Congress could decide that public funds made available under the food stamp program should not go to a household containing an individual who is unrelated to any other member of the household.
I do not believe that asserted congressional concern with the fraudulent use of food stamps is, when interpreted in the light most favorable to sustaining the limitation, quite as irrational as the Court seems to believe. A basic unit which Congress has chosen for determination of availability for food stamps is the “household,” a determination which is not criticized by the Court. By the limitation here challenged, it has singled out households which contain unrelated persons and made such households ineligible. I do not think it is unreasonable for Congress to conclude that the basic unit which it was willing to support with federal funding through food stamps is some variation on the family as we know it— a household consisting of related individuals. This unit provides a guarantee which is not provided by households containing unrelated individuals that the household exists for some purpose other than to collect federal food stamps.
Admittedly, as the Court points out, the limitation will make ineligible many households which have not been formed for the purpose of collecting federal food stamps, and will at the same time not wholly deny food stamps to those households which may have been formed in large part to take advantage of the program. But, as the Court concedes, “[traditional equal protection analysis does not require that every classification be drawn with precise “mathematical nicety/ ” ante, at 538. And earlier this Term, the constitutionality of a similarly “imprecise” rule promulgated pursuant to the Truth in Lending Act was chai- *547 lenged on grounds such as those urged by appellees here. In Mourning v. Family Publications Service, Inc., 411 U. S. 356 (1973), the imposition of the rule on all members of a defined class was sustained because it served to discourage evasion by a substantial portion of that class of disclosure mechanisms chosen by Congress for consumer protection.
The limitation which Congress enacted could, in the judgment of reasonable men, conceivably deny food stamps to members of households which have been formed solely for the purpose of taking advantage of the food stamp program. Since the food stamp program is not intended to be a subsidy for every individual who desires low-cost food, this was a permissible congressional decision quite consistent with the underlying policy of the Act. The fact that the limitation will have unfortunate and perhaps unintended consequences beyond this does not make it unconstitutional.