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.