United States Department of Agriculture v. Murry

Background

A federal agency responsible for the food stamp program defended a 1971 law provision that made any household ineligible if it included a person 18 or older who had been claimed as a dependent on someone else’s federal tax return. Several low-income mothers and young adults — many with almost no income and some receiving public assistance — sued after being denied benefits because ex-spouses or parents had claimed household members as dependents in prior-year tax returns. A three-judge District Court found the provision unconstitutional, and the Supreme Court reviewed the case.

Reasoning

The central question was whether automatically cutting off benefits based on a prior tax claim was constitutional. The Court held that the law created an irrebuttable presumption that the denied household was not needy, and that the program refused hearings or factual inquiries. The majority concluded a parent’s prior-year tax deduction is not a rational measure of a different household’s present need, and it relied on earlier decisions protecting individuals from categorical, unchallengeable presumptions. The Supreme Court affirmed the District Court’s judgment invalidating the tax-dependency rule.

Real world impact

The ruling prevents automatic denial of food stamps solely because someone in a household was claimed as a dependent on another person’s tax return. Agencies must not apply an unchallengeable presumption of nonneed and should allow individualized review so truly needy households are not cut off. The decision affects how the food stamp program is administered and limits a quick administrative shortcut Congress had adopted.

Dissents or concurrances

Justices Stewart and Marshall joined the judgment stressing procedural fairness and the need for individualized review; Justices Blackmun and Rehnquist dissented, arguing the statute had a rational basis to prevent abuse and could be enforced or handled by hearings.