Lyng v. Castillo

LOCATION: Hardwick's Apartment

DOCKET NO.: 85-250
DECIDED BY: Burger Court (1981-1986)

CITATION: 477 US 635 (1986)
ARGUED: Apr 29, 1986
DECIDED: Jun 27, 1986

Jeffrey P. Minear - on behalf of the appellant, pro hac vice
Maria Norma Martinez - on behalf of the appellees

Facts of the case


Media for Lyng v. Castillo

Audio Transcription for Oral Argument - April 29, 1986 in Lyng v. Castillo

Warren E. Burger:

We will hear arguments next in Lyng against Castillo.

Mr. Minear, I think you may proceed whenever you are ready.

Jeffrey P. Minear:

Thank you, Mr. Chief Justice, and may it please the Court, the government defends the constitutionality of Section 3(i) of the Food Stamp Act, which provides that parents and children or siblings who live together shall be treated as a single household for food stamp entitlement purposes.

This case is here on the government's direct appeal from the United States District Court for the Southern District of Texas.

The District Court ruled that Section 3(i) violates equal protection principles by discriminating against families and by impermissibly burdening family decisions to live together.

After briefly describing the food stamp program and the facts of this case, I will explain why the District Court's decision should be reversed.

The Food Stamp Act establishes a social welfare program funded by the Department of Agriculture and administered by state agencies.

It supplements the food purchasing power of low income households.

Under this program state agencies distribute food stamps to needy households on the basis of standard allotments that take into account household size.

The food stamp program has grown rapidly since its creation in 1964.

It is now the nation's second most costly needs-based public assistance program.

In 1983, program outlays were over $11 billion, providing assistance to over 21 million program participants.

The huge cost and dramatic growth of the food stamp program have produced public concern over reports of widespread waste and fraud.

In 1981 and again in 1982 Congress amended the Food Stamp Act to improve program efficiency and to curtail certain types of frequently encountered recipient abuse.

Congress gave particular attention to the Food Stamp Act's definition of the term "household".

Prior to 1981, persons who lived together but purchased and prepared their meals separately could claim separate household status, and thereby receive higher per capita benefits.

As a result families frequently mischaracterized their members as separate households to obtain additional food stamps.

Congress in response amended the household definition to provide that parents and children or siblings who live together shall be treated as one household for food stamp entitlement purposes regardless of their actual meal purchase and preparation habits.

Congress also provided a special exception, permitting elderly and disabled parents and siblings to qualify as a separate household if they in fact did separately prepare their meals.

These amendments to the household definition were specifically designed to assure the nation's limited welfare resources were efficiently distributed to those in greatest need.

Appellee Natividad Castillo and his family challenged the constitutionality of the revised household definition.

They claimed that the new definition violated equal protection principles by denying certain family members the opportunity to claim separate household status.

The District Court consolidated their action with three other suits raising similar equal protection claims.

The District Court ultimately held that the household definition is unconstitutional, and enjoined its application against the appellees.

The court acknowledged that Section 3(i)'s treatment of family members had a rational basis, therefore it meets the generally applicable equal protection requirements.

The court concluded, however, that family-based classifications are subject to heightened scrutiny.

It then held without further analysis that Section 3(i) violated the appellees' Fifth Amendment rights.

William J. Brennan, Jr.:

Is there anything in the record, Mr. Minear, which shows the difference in cost between the two programs?

Jeffrey P. Minear:

It is not clear from the record, but it is clear from the regulations themselves, and the regulations provide, for instance, that an eight-member household would receive 75 percent of the benefits that would be given to eight separate households, and that two four-member households receive 110 percent of the benefits of the eight-member household.

We submit that the District Court erred in concluding that Section 3(i) violates equal protection principles.