## Facts

- Congress amended the Food Stamp Act to make a household ineligible if it included a member age 18 or older who was claimed as a dependent for federal income-tax purposes by a taxpayer who was not a member of an eligible household, for the tax year claimed and one year afterward.
- The amendment was aimed at preventing participation by non-needy households and perceived abuses involving college students and children of wealthy parents.
- Lula Mae Murry lived with two sons and ten grandchildren and had very low monthly income; her household otherwise met program eligibility and was in need.
- Murry was denied food stamps because her ex-husband claimed two of her sons and one grandchild as dependents on his 1971 tax return, and the presence of a household member age 18 or older triggered the statutory bar.
- Other plaintiffs in similar financial circumstances were also denied benefits because ex-husbands claimed as dependents children who lived with the mothers.

## Issues

1. Whether the Fifth Amendment’s Due Process Clause permits Congress to categorically deny food stamps based on prior-year tax-dependency status of an 18-or-older household member claimed by a nonhousehold taxpayer.
2. Whether the statute’s conclusive reliance on tax-dependency status, without any opportunity to show actual present need, is an irrational and unconstitutional irrebuttable presumption.

## Decision

- The Supreme Court affirmed the three-judge district court’s judgment invalidating the challenged provision.
- The Court held that the tax deduction taken by a parent in a prior year is not a rational measure of the need of a different household in which the dependent lives.
- Because the statutory scheme allowed no hearing to show that the tax-dependency fact was irrelevant to the household’s actual need, the provision violated due process.

## Legal Principles

- Federal benefit eligibility criteria must bear a rational relationship to the condition they purport to measure when used to exclude otherwise eligible applicants.
- A statutory rule that creates a conclusive presumption of a decisive fact (here, non-need) and forecloses any opportunity to rebut it can violate due process.
- Prior-year tax-dependency status, standing alone, is an irrational proxy for present need in a separate household when it operates to deny benefits mechanically.

## Conclusion

The Court held that Congress could not deny food stamps to otherwise eligible, needy households solely because a nonhousehold taxpayer previously claimed an adult child as a tax dependent, where the program provided no mechanism to prove that the tax-dependency designation did not reflect current need.


U.S. Dep’t of Agric. v. Murry, 413 U.S. 508 (1973)