USDA v. Moreno

Week 11 — Equal Protection — Rational Basis (with Bite)

Facts

  • Congress altered the requirements for households to be eligible for food stamps.
  • It was undisputed that the purpose of the amendment was to prevent "hippie communes" from utilizing the benefits.

Issue

Whether the food-stamp amendment, motivated by animus against hippies, satisfied rational basis review under the Equal Protection Clause.

Holding

No. The amendment was unconstitutional under the EPC.

Reasoning

  • Under rational basis "with bite"—triggered when a traditionally unpopular group is targeted—the classification made must clearly be relevant to the stated purpose of the government action.
  • Because there was no legitimate purpose other than animus against hippies, the law failed.
  • A bare congressional desire to harm or discriminate against a politically unpopular group is not a legitimate government interest.

Notes

  • Moreno is a foundational rational basis "with bite" case.
  • The "hippie commune" target classification did not warrant strict or intermediate scrutiny, but the Court still struck the law down at the rational basis level after finding that it was rooted in animus.