Lyng v. Castillo

Citation91 L.Ed.2d 527,106 S.Ct. 2727,477 U.S. 635
Decision Date27 June 1986
Docket NumberNo. 85-250,85-250
PartiesRichard E. LYNG, Secretary of Agriculture, Appellant v. Natividad CASTILLO et al
CourtUnited States Supreme Court
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 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.

Jeffrey P. Minear, for appellant, pro hac vice, by special leave of court.

Maria Norma Martinez, San Antonio, Tex., for appellees.

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

I

Appellees are families who generally buy their food and prepare their meals as separate 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 timeconsuming; 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, 93 S.Ct. 2821, 2825, 37 L.Ed.2d 782 (1973), a 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, 106 S.Ct. 1511, 89 L.Ed.2d 911 (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, 96 S.Ct. 2562, 2566-2567, 49 L.Ed.2d 520 (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, 98 S.Ct. 673, 681, and n. 12 (1978). See id., at 403-404, 98 S.Ct., at 690 (STEVENS, J., concurring); Califano v. Jobst, 434 U.S. 47, 58, 98 S.Ct. 95, 101, 54 L.Ed.2d 228 (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 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 interest." 413 U.S., at 533, 93 S.Ct., at 2825. See id., at 533-538, 93 S.Ct., at 2825-2827.3

Under the proper standard of review, we agree with the District Court that Congress had a rational basis both for treating parents, children and siblings who live together as a single "household," and for applying a different standard in determining whether groups of more distant relatives and unrelated persons living together constitute a "household."

As a general matter, the economies of scale that may be realized in group purchase and preparation of food surely justified Congress in providing additional food stamp benefits to households that could not achieve such efficiencies.4 Moreover, the Legislature's recognition of the potential for mistake and fraud 5 and the cost-ineffectiveness of case-by-case verification of claims that individuals ate as separate house- holdsS6 unquestionably warrants the use of general definitions in this area.7

The question that remains is whether Congress could accommodate the wishes of distant relatives and unrelated individuals to dine separately without invidiously discriminating against close relatives.8 The question, in other words, is whether Congress could "[l]imi[t] the availability of the 'purchase and prepare food separately' rule to those most likely to actually be separate households, although living together with others for reasons of economy or health (i.e., [distant relatives and] unrelated persons)." S.Rep. No. 97-504, p. 25 (1982), U.S.Code Cong. & Admin.News 1982, p. 1663.

So stated, the justification for the statutory classification is obvious. Congress could reasonably determine that close relatives sharing a home—almost by definition—tend to purchase and prepare meals together while distant relatives and unrelated individuals might not be so inclined. In that event, even though close relatives are undoubtedly as honest as other food stamp recipients, the potential for mistaken or misstated claims of separate dining would be greater in the case of close relatives than would be true for those with weaker communal ties, simply because a greater percentage of the former category in fact prepare meals jointly than the comparable percentage in the latter category. The additional fact that close relatives represent by far the largest proportion of food stamp recipients 9 might well have convinced Congress that limited funds would not permit the accommodation given distant relatives and unrelated persons to be stretched to embrace close relatives as well.10 Finally Congress might have reasoned that it would be somewhat easier for close relatives—again, almost by definition—to accommodate their living habits to a federal policy favoring common meal...

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