Facts
- Congress enacted § 109 of the Omnibus Budget Reconciliation Act of 1981, amending the Food Stamp Act.
- The amendment provided that a household could not become newly eligible for food stamps, or receive an increased allotment, while any member was on strike and the striker’s income decline was the basis for eligibility or increase.
- A labor union and affected members challenged the amendment as unconstitutional under the First Amendment (association and expression) and the equal protection component of the Fifth Amendment.
- A federal district court granted summary judgment for the challengers and declared the statute unconstitutional.
- The Secretary of Agriculture appealed directly to the Supreme Court.
Issues
- Whether § 109 unconstitutionally burdened associational rights by making households with a striking member ineligible for new or increased food stamp benefits.
- Whether § 109 abridged expressive rights by economically burdening the decision to strike.
- Whether § 109 violated equal protection principles under the Fifth Amendment by treating households with strikers differently from other households.
Decision
- The Supreme Court reversed the judgment and upheld § 109 as constitutional.
- The Court held the statute did not directly and substantially interfere with family living arrangements or the ability of workers to associate to conduct a strike.
- The Court held the statute did not suppress or compel speech; it merely declined to provide additional benefits because a strike reduced income.
- The Court applied rational basis review and found the classification rationally related to a legitimate governmental interest in remaining neutral in private labor disputes.
Legal Principles
- The government’s refusal to subsidize conduct associated with a constitutional right generally does not, without more, infringe that right.
- A benefits classification affecting strike-related economic consequences does not violate the First Amendment absent direct and substantial interference with association or coercion of expression.
- When no suspect class or fundamental right is targeted by a benefits classification, the equal protection component of the Fifth Amendment is satisfied if the law is rationally related to a legitimate governmental purpose, including maintaining neutrality in labor disputes.
Conclusion
The Court upheld Congress’s decision to deny new or increased food stamp benefits to households with striking members, holding that the measure neither infringed First Amendment rights nor failed rational basis review under the Fifth Amendment’s equal protection component.