U.S. Dept. of Agriculture v. Moreno
413 U.S. 528 (1973)

  • Under the Food Stamp Act, the poor would receive credits to buy food. The eligibility was determined on the basis of overall ‘household’ income, not individual income.
    • When the law was passed, §3(e) defined a ‘household’ to include unrelated, unmarried people living together, as long as they shared household expenses.
    • A few years later, Congress modified the definition to only include related and married people as a household.
      • Legislative history shows that Congress modified §3(e) to stop “hippies” and “hippie communes” from being about to take advantage of the program.
  • Moreno et. al. sued, claiming that the change was an unconstitutional violation of the Equal Protection Clause of the 14th Amendment.
    • The change created two classes of people, those related to their roommates, and those who weren’t. Those who weren’t related were at a disadvantage.
  • The US Supreme Court found the change to be unconstitutional.
    • The US Supreme Court found that that to withstand judicial scrutiny on equal protection grounds, a law must bear a rational relation to some legitimate end.
      • That’s the rational basis test, which is the lowest level of judicial scrutiny.
    • In this case, the Court found that the classification was clearly irrelevant to the stated purposes of the Food Stamp Act and not rationally furthering any other legitimate governmental interest.
      • The purpose of the Food Stamp Act was to stop people from going hungry, and there was no basis for not allowing unrelated people to take advantage of the program.
  • In general, the courts rarely overturn a law because it can’t meet the rational basis test. The bar is usually pretty low.