Lyng v. International Union, United Automobile, Aerospace, & Agricultural Implement Workers
Headline: Court upholds 1981 rule barring households with striking workers from gaining extra food stamps, allowing Congress to limit benefits to save money and avoid subsidizing private labor disputes.
Holding:
- Allows Congress to deny increased food stamps to households while a member strikes.
- Makes striking workers’ families less likely to receive additional federal food assistance during strikes.
- Signals courts will defer to Congress on budgetary classifications for welfare programs.
Summary
Background
A 1981 change to the federal food stamp law says a household cannot become eligible or get a larger allotment while any household member is on strike. In 1984 two labor unions and several union members sued the Secretary of Agriculture, arguing the rule violated the First Amendment (association and expression) and the Fifth Amendment’s equal protection guarantee. A District Court struck down the amendment; the Government appealed directly to the Supreme Court.
Reasoning
The Court addressed whether the strike rule substantially burdens associational or expressive rights and whether it is constitutionally irrational. The majority concluded the law does not directly and substantially interfere with union association or expression and therefore applied the deferential rational-basis review. It found three legitimate objectives: reduce federal spending, target limited aid to greatest need, and avoid appearing to subsidize one side in private labor disputes. The Court upheld the statute as rationally related to those objectives and noted two provisos that preserve some prior eligibility.
Real world impact
As a result, households with a member on strike cannot increase food stamp allotments because of the striker’s lost income. The decision leaves Congress free to make budget-driven eligibility choices for federal assistance and affirms the Government’s authority to limit subsidies during labor disputes. The Supreme Court reversed the District Court’s invalidation, and Justice Kennedy did not take part in the decision.
Dissents or concurrances
Justice Marshall (joined by Brennan and Blackmun) dissented, arguing the rule fails even rational-basis review, harms needy children and families, and reflects anti-strike animus rather than legitimate policymaking.
Opinions in this case:
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