Lyng v. Castillo
Encyclopedia
Lyng v. Castillo, 477 U.S. 635
(1986), reversed a lower court's decision that the change in the statutory definition of a household
violated the appellee's due process rights. The program rules for food stamps were changed in 1981 and 1982 which changed the definitions of households. The Supreme Court ruled that the District court erred in using heightened scrutiny
to analyze the validity of the household definition.
Earlier, the Supreme Court ruled in Department of Agriculture v. Moreno
, 413 U.S. 528, that the Food Stamp
Act of 1971 had an unconstitutional definition of household which would reduce or eliminate benefits if an unrelated individual lived in the household.
) tenants or sub leasers, non-legally related minors and non-married spouses. The plaintiffs argued that these groups or some of them should be included in proposals for eligibility and quantity of aid supplied.
" means (1) an individual who lives alone or who, while living with others, customarily purchases foods and prepares meals for home consumption separate and apart from the others, or (2) a group of individuals who live together and customarily purchase food and prepare meals together for home consumption; except that parents and children, or siblings, who live together shall be treated as a group of individuals who customarily purchase and prepare meals together for home consumption even if they do not do so, unless one of the parents, or siblings, is an elderly or disabled member."
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. 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.
, White
, and Marshall
all authored dissenting opinions.
When it moved beyond the rule that merely grouped parents and children, and, in the 1982 amendments, grouped siblings together as well, Congress interfered substantially with the desires of demonstrably separate families to remain separate families. It did so, moreover, while recognizing that distinct families living together often are genuinely separate households, and that the food stamp program should permit separate families that are not related to live together, but maintain separate households. S.Rep. No. 97-504, at 25. Congress nevertheless assumed that related families are less likely to be genuinely separate households than are unrelated families, and failed even to provide related families a chance to rebut the legislative presumption. In view of the importance to the affected families of their family life and their very survival, the Court's extreme deference to this untested assumption is simply inappropriate. I respectfully dissent."
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1986), reversed a lower court's decision that the change in the statutory definition of a household
Household
The household is "the basic residential unit in which economic production, consumption, inheritance, child rearing, and shelter are organized and carried out"; [the household] "may or may not be synonymous with family"....
violated the appellee's due process rights. The program rules for food stamps were changed in 1981 and 1982 which changed the definitions of households. The Supreme Court ruled that the District court erred in using heightened scrutiny
Intermediate scrutiny
Intermediate scrutiny, in U.S. constitutional law, is the second level of deciding issues using judicial review. The other levels are typically referred to as rational basis review and strict scrutiny ....
to analyze the validity of the household definition.
Earlier, the Supreme Court ruled in Department of Agriculture v. Moreno
Department of Agriculture v. Moreno
Department of Agriculture v. Moreno, , was a case before the United States Supreme Court.-Facts:Appellees consisted of several groups of individuals who alleged that, although they satisfied the income eligibility requirements for federal food assistance, they were nevertheless excluded from the...
, 413 U.S. 528, that the Food Stamp
Food Stamp Program
The United States Supplemental Nutrition Assistance Program , historically and commonly known as the Food Stamp Program, is a federal-assistance program that provides assistance to low- and no-income people and families living in the U.S. Though the program is administered by the U.S. Department of...
Act of 1971 had an unconstitutional definition of household which would reduce or eliminate benefits if an unrelated individual lived in the household.
Background of case
Eligibility for the federal food stamp program is determined on a “household” basis. However, the exact definition of the term "household" fluctuates and may not include all people living on the same property. Those that are not figured into the discussion include distant family members (farther than first cousinCousin
In kinship terminology, a cousin is a relative with whom one shares one or more common ancestors. The term is rarely used when referring to a relative in one's immediate family where there is a more specific term . The term "blood relative" can be used synonymously and establishes the existence of...
) tenants or sub leasers, non-legally related minors and non-married spouses. The plaintiffs argued that these groups or some of them should be included in proposals for eligibility and quantity of aid supplied.
Disputed Phrasing
"HouseholdHousehold
The household is "the basic residential unit in which economic production, consumption, inheritance, child rearing, and shelter are organized and carried out"; [the household] "may or may not be synonymous with family"....
" means (1) an individual who lives alone or who, while living with others, customarily purchases foods and prepares meals for home consumption separate and apart from the others, or (2) a group of individuals who live together and customarily purchase food and prepare meals together for home consumption; except that parents and children, or siblings, who live together shall be treated as a group of individuals who customarily purchase and prepare meals together for home consumption even if they do not do so, unless one of the parents, or siblings, is an elderly or disabled member."
Majority opinion
Justice Stevens, writing for the Court, ruled that since it was possible for those not included within the household were able to separately eligible to petition for the federal food stamp program, they would not be considered in federal food stamp applications.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. 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.
Dissenting opinions
Justices BrennanWilliam J. Brennan, Jr.
William Joseph Brennan, Jr. was an American jurist who served as an Associate Justice of the United States Supreme Court from 1956 to 1990...
, White
Byron White
Byron Raymond "Whizzer" White won fame both as a football halfback and as an associate justice of the Supreme Court of the United States. Appointed to the court by President John F. Kennedy in 1962, he served until his retirement in 1993...
, and Marshall
Thurgood Marshall
Thurgood Marshall was an Associate Justice of the United States Supreme Court, serving from October 1967 until October 1991...
all authored dissenting opinions.
Brennan
"I would affirm on the ground that the challenged classifications violate the Equal Protection Clause because they fail the rational basis test."White
"For the reasons given in the last three paragraphs of Justice Marshall’s dissenting opinion, the classification at issue in this case is irrational. Accordingly, I dissent."Marshall
"This case demonstrates yet again the lack of vitality in this Court's recent equal protection jurisprudence.When it moved beyond the rule that merely grouped parents and children, and, in the 1982 amendments, grouped siblings together as well, Congress interfered substantially with the desires of demonstrably separate families to remain separate families. It did so, moreover, while recognizing that distinct families living together often are genuinely separate households, and that the food stamp program should permit separate families that are not related to live together, but maintain separate households. S.Rep. No. 97-504, at 25. Congress nevertheless assumed that related families are less likely to be genuinely separate households than are unrelated families, and failed even to provide related families a chance to rebut the legislative presumption. In view of the importance to the affected families of their family life and their very survival, the Court's extreme deference to this untested assumption is simply inappropriate. I respectfully dissent."
Continued Controversy
Lyng v. Castillo has again been brought up in recent news. The ruling of the court is preventing same-sex couples living in the same residence from applying from to the federal food stamp program together. They are still able to apply and qualify to receive benefits however they are not recognized similarly to heterosexual couples living together.See also
- List of United States Supreme Court cases, volume 477
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court