Department of Agriculture v. Moreno

Department of Agriculture v. Moreno, 413 U.S. 528 (1973), was a United States Supreme Court case that declared a provision of the Food Stamp Act denying food stamps to households of "unrelated persons" to be a violation of the U.S. Constitution. The Court held that provision to be irrelevant to the stated purpose of the statute and in violation of the Due Process Clause of the Fifth Amendment.

Background

The case was brought by several groups of individuals; they alleged that they satisfied the income eligibility requirements for federal food assistance, but they were excluded from the program solely because the persons in each group were not all related to one another.

Eligibility for participation in the federal food stamp program was based on households rather than individuals. Under Section 3(e) of the Food Stamp Act (7 USC 2012(e)), the term "household" was defined to include only groups whose members were all related to one another.

The plaintiffs were members of groups of individuals with the need for food stamp assistance who were denied food stamps because the groups included members who were not all related to one another. For example, one plaintiff, a 56-year-old diabetic woman, lived with, shared common living expenses with, and received medical care from another woman with three children, each woman receiving a small monthly income from public assistance. Another plaintiff, an indigent married woman with three children, took in a 20-year-old girl, who was unrelated to them, because they felt that she had emotional problems. Another plaintiff, whose daughter had an acute hearing deficiency and required special instruction in a school for the deaf, decided that to make the most of her limited resources, she would share an apartment near the school with another woman, each woman being a recipient of public assistance.