## Facts

- Congress enacted the Food Stamp Act of 1964 to improve nutrition among low-income households and to increase use of agricultural surpluses.
- The Act originally defined an eligible “household” broadly, including related or unrelated persons living together as a single economic unit.
- In 1971, Congress amended § 3(e), 7 U.S.C. § 2012(e), making most households ineligible if they contained any individual unrelated to the other members.
- The Department of Agriculture implemented regulations denying benefits to households whose members were not all related to each other.
- Jacinta Moreno lived with an unrelated adult and that adult’s children, shared expenses, and otherwise met program income requirements, but benefits were denied solely due to the presence of unrelated household members.
- A class of similarly situated applicants and recipients faced denial or termination of food stamps under the amendment.

## Issues

1. Whether the 1971 amendment to the Food Stamp Act excluding households containing unrelated members violates the equal protection component of the Fifth Amendment’s Due Process Clause.

## Decision

- The Supreme Court affirmed the judgment invalidating § 3(e)’s “unrelated person” exclusion.
- Applying rational basis review, the Court held the classification was not rationally related to the Act’s stated purposes of improving nutrition and supporting agricultural distribution.
- The Court rejected the government’s primary justification that the exclusion served fraud prevention, concluding it did not reasonably target likely fraud and instead disproportionately harmed those unable to change living arrangements.
- The Court stated that a bare legislative desire to harm a politically unpopular group is not a legitimate governmental interest and cannot sustain a statutory classification.

## Legal Principles

- Under the Fifth Amendment’s equal protection component, federal statutory classifications not involving suspect classes or fundamental rights must bear a rational relationship to a legitimate governmental interest.
- Preventing fraud can be a legitimate governmental objective, but a classification must reasonably advance that objective in operation, not merely in assertion.
- Legislative hostility toward a politically unpopular group, standing alone, is not a legitimate governmental interest and cannot justify differential treatment, even under rational basis review.

## Conclusion

The Court struck down the Food Stamp Act’s exclusion of households with unrelated members because the classification was unrelated to the program’s stated purposes, was not a rational anti-fraud measure in practice, and could not be justified by animus toward a disfavored group.


U.S. Dep’t of Agric. v. Moreno, 413 U.S. 528 (1973)