Friday, November 15, 2013

U.S. Dept. of Agriculture v. Moreno case brief

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

CASE SYNOPSIS
Appellants sought review of the judgment from the United States District Court for the District of Columbia, holding that the related household limitation of § 3 of the Food Stamp Act of 1964, 7 U.S.C.S. § 2012 was invalid as violative of the Due Process Clause of the Fifth Amendment.

CASE FACTS
Appellees consisted of several groups of individuals who alleged that, although they satisfied the income eligibility requirements for federal food assistance, they were nevertheless excluded from the program solely because the persons in each group were not all related to each other. The district court held that the "unrelated person" provision of 7 U.S.C.S. § 2012(e) created an irrational classification in violation of the equal protection component of the Due Process Clause of the Fifth Amendment.

DISCUSSION

  • On certiorari, the Court affirmed, holding that the "unrelated person" provision was irrelevant to the state purpose of the Food Stamp Act and did not operate to rationally further the prevention of fraud. 
  • The classification acted to exclude not only those who were likely to abuse the program, but also those who were in need of the aid but could not afford to alter their living arrangements so as to retain their eligibility.

CONCLUSION

The Court affirmed the district court's determination that the unrelated household classification was invalid because it was irrelevant to the stated purpose of the Food Stamp Act and was not rationally related to furthering any legitimate government interest.

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