## Facts

- Federal food stamp eligibility and benefit amounts are calculated on a “household,” not an individual, basis.
- Congress amended the Food Stamp Act to treat parents and children, and siblings, who live together as a single household, regardless of whether they actually purchase and prepare meals together (with a narrow elderly/disabled exception).
- Other co-resident groups (more distant relatives or unrelated persons) were treated as one household only if they customarily purchased food and prepared meals together.
- Several families consisting of co-resident parents/children or siblings operated as separate economic units and generally bought and prepared food separately.
- Because the statute required these close relatives to be counted as one household, some families faced reduced benefits or loss of eligibility.
- The families challenged the classification as violating equal protection as applied through the Fifth Amendment’s Due Process Clause.

## Issues

1. Whether co-resident parents/children and siblings constitute a suspect or quasi-suspect class requiring heightened scrutiny under the Fifth Amendment’s equal protection component.
2. Whether the household definition directly and substantially interferes with family living arrangements so as to burden a fundamental right and trigger heightened scrutiny.
3. Whether, if rational basis review applies, Congress had a legitimate and rational reason to presume close co-resident relatives form a single household for food stamp purposes.

## Decision

- The Supreme Court reversed the district court.
- The Court held that co-resident parents/children and siblings are not a suspect or quasi-suspect class.
- The Court held the statute did not directly and substantially interfere with family living arrangements; it did not prohibit cohabitation or impose penalties for living together, but only set benefit-calculation rules.
- Applying rational basis review, the Court upheld the classification as rationally related to legitimate administrative and program objectives.

## Legal Principles

- Equal protection analysis under the Fifth Amendment follows the same framework used under the Fourteenth Amendment.
- Heightened scrutiny applies only if a law targets a suspect/quasi-suspect class or burdens a fundamental right.
- A law affecting family choices triggers heightened scrutiny only when it “directly and substantially” interferes with family living arrangements.
- Under rational basis review, socioeconomic classifications are valid if Congress could reasonably believe they serve legitimate governmental purposes; perfect fit or empirical certainty is not required.
- Congress may employ administrable presumptions in welfare programs, including presuming close relatives living together are more likely to purchase and prepare meals together than other co-resident groupings.

## Conclusion

The Court upheld the Food Stamp Act’s rule treating co-resident parents/children and siblings as a single household, holding that the classification neither involved a suspect class nor directly and substantially burdened family living arrangements, and that it was rationally related to legitimate administrative goals in determining benefits.


Lyng v. Castillo, 477 U.S. 635 (1986)