Jacinta Moreno lived with Ermina Sanchez, who was not related, and Sanchez's three children. Sanchez provided care to Moreno, who contributed to household living expenses. Moreno satisfied the income requirements for the federal food stamp program, but was denied under Section 3 of the Food Stamp Act of 1964, amended in 1971, which prohibited households with unrelated members from receiving food stamp benefits. Sanchez's food stamp benefits were also to be terminated. Moreno and other households who were denied benefits under Section 3 challenged the statute in the United States District Court for the District of Columbia. The District Court held that Section 3 violated the Due Process Clause of the Fifth Amendment. The United States appealed.
Does Section 3 of the Food Stamp Act of 1964 violate the equal protection component of the Due Process Clause of the Fifth Amendment?
Yes. In a 7-2 decision, the Court upheld the District Court and maintained that amended Section 3 violated the Fifth Amendment in creating two types of households – one in which all members were related and one in which at least one member was unrelated. Justice William J. Brennan, Jr., writing for the majority, acknowledged the interest of Congress in preventing abuse of the Food Stamp program. However, the statute did not fulfill Congress' stated purpose of preventing "hippies" and "hippie communes" from enrolling the food stamp program. Additionally, there existed other measures within the Food Stamp Act that were specifically aimed at preventing abuse of the program. Since the statute "simply does not operate so as rationally to further the prevention of fraud," the distinction between households with related members and households with unrelated members did not further the state interest and therefore violated the equal protection component of the Due Process Clause of the Fifth Amendment. Justice William O. Douglas authored a concurring opinion.
Decisions
Decision: 7 votes for Moreno, 2 vote(s) against Legal provision: 7 U.S.C. 2012
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Full Opinion by Justice William J. Brennan, Jr.
