477 U.S. 635 (1986), 85-250, Lyng v. Castillo

Docket Nº:No. 85-250
Citation:477 U.S. 635, 106 S.Ct. 2727, 91 L.Ed.2d 527, 54 U.S.L.W. 4864
Party Name:Lyng v. Castillo
Case Date:June 27, 1986
Court:United States Supreme Court
 
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Page 635

477 U.S. 635 (1986)

106 S.Ct. 2727, 91 L.Ed.2d 527, 54 U.S.L.W. 4864

Lyng

v.

Castillo

No. 85-250

United States Supreme Court

June 27, 1986

Argued April 29, 1986

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR

THE SOUTHERN DISTRICT OF TEXAS

Syllabus

Eligibility and benefit levels in the federal food stamp program are determined on a "household," rather than an individual, basis. The statutory definition of the term "household," as amended in 1981 and 1982, generally treats parents, children, and siblings who live together as a single household, but does not treat more distant relatives, or groups of unrelated persons who live together, as a single household unless they also customarily purchase food and prepare meals together. Appellees are families who generally buy their food and prepare their meals as separate economic [106 S.Ct. 2728] units, and who will either lose benefits or have their food stamp allotment decreased as a result of the 1981 and 1982 amendments to the statute. They filed actions that were consolidated in Federal District Court, claiming that the statutory distinction between parents, children, and siblings and all other groups of individuals violates the guarantee of equal treatment in the Due Process Clause of the Fifth Amendment. On cross-motions for summary judgment, the District Court, applying "heightened scrutiny," invalidated the distinction.

Held: The statutory distinction is not unconstitutional. The District Court erred in judging its constitutionality under "heightened scrutiny," since close relatives are not a "suspect" or "quasi-suspect" class. The statutory distinction does not "directly and substantially" interfere with family living arrangements, and thereby burden a fundamental right. Judged under the proper standard of review, Congress had a rational basis for making the distinction, since it could reasonably determine that close relatives sharing a home tend to purchase and prepare meals together, while distant relatives and unrelated individuals might not be so inclined. Pp. 638-643.

Reversed.

STEVENS, J., delivered the opinion of the Court, in which BURGER, C.J., and BLACKMUN, POWELL, REHNQUIST, and O'CONNOR, JJ., joined. BRENNAN, J., post, p. 643, WHITE, J., post, p. 643, and MARSHALL, J., post, p. 643, filed dissenting opinions.

Page 636

STEVENS, J., lead opinion

JUSTICE STEVENS delivered the opinion of the Court.

Eligibility and benefit levels in the federal food stamp program are determined on a "household," rather than an individual, basis. The statutory definition of the term "household," as amended in 1981 and 1982, generally treats parents, children, and siblings who live together as a single household, but does not treat more distant relatives, or groups of unrelated persons who live together, as a single household unless they also customarily purchase food and prepare meals together.1 Although there are variations in the facts of the four cases that were consolidated in the District Court, they all raise the question whether the statutory distinction between parents, children, and siblings, and all other groups of individuals violates the guarantee of equal treatment in the Due Process Clause of the Fifth Amendment.2

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I

Appellees are families who generally buy their food and prepare their meals as separate [106 S.Ct. 2729] economic units; each family will either lose its benefits or have its food stamp allotment decreased as a result of the 1981 and 1982 amendments. Moreover, as appellees' counsel eloquently explained, in each case, the loss or reduction of benefits will impose a severe hardship on a needy family, and may be especially harmful to the affected young children for whom an adequate diet is essential.

Appellees accordingly filed these lawsuits to invalidate the 1981 and 1982 amendments and to be treated as separate households for the purpose of determining eligibility and allotment of food stamps. On cross-motions for summary judgment, the District Court considered the merits of appellees' challenge to the constitutionality of the "household" definition.

The District Court was persuaded that the statutory definition had a rational basis. It observed that the amendment made it more difficult for individuals who live together to "manipulate" the rules "so as to obtain separate household status and receive greater benefits"; that the administrative burden of "attempting to make individual household determinations as to `household' status" was time-consuming; and that unrelated persons who live together for reasons of economy or health are more likely "`to actually be separate households'" than related families who live together. App. to Juris. Statement 5a-6a. It held, however, that "a stricter standard of review than the `rational basis' test" was required. Id. at 7a. Relying primarily on United States Dept. of Agriculture v. Moreno, 413 U.S. 528, 534 (1973), a

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case which it construed as holding that a "congressional desire to harm a politically unpopular group" could not justify the exclusion of household groups which contained unrelated persons, the District Court reasoned that,

if the Supreme Court is willing to protect unpopular political groups, it should even be more willing to protect the traditional family value of living together.

App. to Juris. Statement 8a.

We noted probable jurisdiction, 474 U.S. 994 (1985), and now reverse.

II

The District Court erred in judging the constitutionality of the statutory distinction under "heightened scrutiny." The disadvantaged class is that comprised by parents, children, and siblings. Close relatives are not a "suspect" or "quasi-suspect" class. As a historical matter, they have not been subjected to discrimination; they do not exhibit obvious, immutable, or distinguishing characteristics that define them as a discrete group; and they are not a minority, or politically powerless. See, e.g., Massachusetts Board of Retirement v. Murgia, 427 U.S. 307, 313-314 (1976) (per curiam). In fact, quite the contrary is true.

Nor does the statutory classification "directly and substantially" interfere with family living arrangements, and thereby burden a fundamental right. Zablocki v. Redhail, 434 U.S. 374, 386-387, and n. 12 (1978). See id. at 403-404 (STEVENS, J., concurring); Califano v. Jobst, 434 U.S. 47, 58 (1977). The "household" definition does not order or prevent any group of persons from dining together. Indeed, in the overwhelming majority of cases, it probably has no effect at all. It is exceedingly unlikely that close relatives would choose to live apart simply to increase their allotment of food stamps, for the cost of separate housing would almost certainly exceed the incremental value of the additional stamps. See 50 Fed.Reg. 36641, 36642 (1985). Thus, just as in

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United States Dept. of Agriculture v. Moreno -- the decision which the District Court read to require "heightened scrutiny" -- the "legislative classification must be sustained if the classification itself is rationally related to a legitimate governmental [106 S.Ct. 2730] interest." 413 U.S. at 533. See id. at 533-538.3

Under the proper standard of review, we agree with the District Court that Congress had a rational basis both for treating parents, children, and...

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