413 U.S. 508 (1973) |
SCOTUS decided 1973-06-25
Food Stamp Act violates due process because a standard is not a rational measure of need and the administration of the Act allows no hearing to show that the standard is irrelevant to the need of the household.Result: Win
Kenneth L. Karst, Encyclopedia of the American Constitution (1986): “Piqued by the activities of protesting students and members of “hippie communes” during the Vietnam years of agony, Congress in 1971 amended the Food Stamp Act to deny eligibility for food subsidies to two classes of applicants: “unrelated” persons living together and persons claimed by others in the previous year as tax dependents. On the same day the Supreme Court struck down both these amendments. Moreno, 7–2, invalidated the “unrelated” limitation on “Fifth Amendment equal protection ” grounds; the amendment was irrelevant to the act’s goals of nourishing the needy and aiding agriculture, and harming “hippies” for their unpopularity was not a legitimate legislative purpose. The law thus lacked a rational basis. Murry, 5–4, held the “tax dependency” limitation an unconstitutional irrebuttable presumption. A claimant might be needy during the current year although dependent on another during a previous year; yet the law denied any opportunity to qualify for aid by demonstrating need.”
Law type: Civil
Topic(s): Due process, Public assistance, and Unrelated persons
State of origin: DC
Ronald F. Pollack (Food Research & Action Center) argued the cause for appellees. With him on the brief was Roger A. Schwartz.
Organization role: Sponsor
Last modified: 2020-04-02 11:27
Case internal grade: A | Case internal status: OK |
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CASE DETAILS(The syllabus is not part of the opinion, but is a summary prepared by the court reporter as a convenience.)
APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Appellees challenge the constitutionality of § 5(b) of the Food Stamp Act of 1964, as amended in 1971, providing that ‘(a)ny household which includes a member who has reached his eighteenth birthday and who is claimed as a dependent child for Federal income tax purposes by a taxpayer who is not a member of an eligible household, shall be ineligible to participate in any food stamp program . . . during the tax period such dependency is claimed and for a period of one year after the expiration of such tax period.’ This provision was generated by congressional concern over nonneedy households participating in the food stamp program, and abuses of the program by ‘college students’ and ‘children of wealthy parents.’ The District Court held the provision unconstitutional, finding that it went far beyond the congressional goal, and operated inflexibly to deny stamps to households, containing no college students, that had established clear eligibility for stamps and remained in dire need, only because a member of the household 18 years or older is claimed by someone as a tax dependent. Held: The tax deduction taken for the benefit of the parent in a prior year is not a rational measure of the need of a different household with which the child of the tax-deducting parent lives, and the administration of the Act allows no hearing to show that the tax deduction is irrelevant to the need of the household. Section 5(b) therefore violates due process. Pp. 511—514.
348 F.Supp. 242, affirmed.
From the opinion
Appellee Murry has two sons and ten grandchildren in her household. Her monthly income is $57.50, which comes from her ex-husband as support for her sons. Her expenses far exceed her monthly income. By payment, however, of $11, she received $128 in food stamps. But she has now been denied food stamps because her ex-husband (who has remarried) had claimed her two sons and one grandchild as tax dependents in his 1971 income tax return. That claim, plus the fact that her eldest son is 19 years old, disqualified her household for food stamps under § 5(b) of the Act. [Footnote 1] Appellee Alderete is in comparable straits because her ex-husband claimed the five children, who live with their mother, as tax dependents, the oldest being 18 years old. Appellee Beavert’s case is similar. Appellee Lee is the mother of five children, her entire income per month being $23 derived from public assistance. Her five children live with her. Her monthly bills are $249, of which $148 goes for food. Her husband is not a member of her household; he, in fact, deserted her, and has supplied his family with no support. But he claimed the two oldest sons, ages 20 and 18, as tax dependents in his 1971 tax return, with the result that the wife’s household was denied food stamps. Appellee Nevarez is in comparable straits.
Appellee Joe Valdez is 18 years old and married, and he and his wife have a child. He lives wholly on public assistance and applied for food stamps. His application was rejected because his father Ben claimed him as a tax dependent in his 1971 income tax return. Joe receives no support from Ben because Ben is in debt, and unable to help support Joe.
Appellee Broderson is 18 and married to a 16-year-old wife, and they have a small child. Their monthly income is $110 consisting of his wages at a service station. He cannot get food stamps because his father claimed him as a tax dependent. The father, however, gives him no support.
Appellee Schultz is 19 years old, and she resides with a girlfriend and the latter’s two children. Appellee Schultz has no income of any kind, but received food stamps for the household where she lived. Food stamps, however, were discontinued when her parents claimed her as a tax dependent but refused to give her any aid. She soon got married, but she and her husband were denied food stamps because her parents had claimed her for tax dependency.
These appellees brought a class action to enjoin the enforcement of the tax dependency provision of the Act, and, as noted, the three-judge court granted the relief.
Appellees are members of households that have been denied food stamp eligibility solely because the households contain persons 18 years or older who have been claimed as “dependents” for federal income tax purposes by taxpayers who are themselves ineligible for food stamp relief. Section 5(b) makes the entire household of which a “tax dependent” was a member ineligible for food stamps for two years: (1) during the tax year for which the dependency was claimed and (2) during the next 12 months. During these two periods of time, § 5(b) creates a conclusive presumption that the “tax dependent’s” household is not needy and has access to nutritional adequacy.