United States Department of Agriculture v. Moreno

Background

The dispute involved the federal food stamp program and a 1971 change that redefined “household” to include only related individuals (with limited exceptions for elderly persons). Several low-income people who lived with unrelated roommates or who took in needy individuals sued after being denied food stamps. The District Court found the rule invalid, and the Supreme Court affirmed that judgment, addressing examples including a 56-year-old diabetic woman, a family who took in a 20-year-old, and a mother sharing housing to get her child to a special school.

Reasoning

The Court asked whether excluding all households that include any unrelated member was rationally tied to the program’s goals of improving nutrition and marketing agricultural products. The Court found the unrelated-person classification irrelevant to those goals, noted legislative comments aimed at excluding “hippie communes,” and rejected that political hostility as a legitimate purpose. The Government’s fraud-prevention argument was rejected because the statute already contained fraud controls and because the rule in practice denied aid to the poorest people who could not afford to rearrange living situations.

Real world impact

By invalidating the unrelated-person exclusion, the decision allows needy people who share housing, double up, or take in others to receive food stamps when otherwise eligible. Agencies cannot broadly exclude applicants solely because some household members are unrelated. The ruling directly affects administration of the national food stamp program going forward.

Dissents or concurrances

Justice Douglas emphasized freedom of association and that the rule punished the poorest who doubled up; Justice Rehnquist dissented, arguing deference to Congress and that fraud concerns could justify the rule.