Lyng v. Castillo

Federal food-stamp program eligibility and benefit amounts are determined by household, not by individual. In 1981, to combat fraud, Congress amended the statutory definition of a single household to mean parents and children who live together. In 1982, Congress expanded the definition to include siblings who live together. Under the amended statute, however, more distant groups of relatives or unrelated persons who lived together were not considered a single household if they purchased and prepared food separately and were therefore entitled to benefits as separate households. After the amendments, close relatives who lived together but bought and prepared their food separately would face loss or decrease in food-stamp benefits because they would be considered a single household. A group of close families who would face such consequences (the close families) (plaintiffs) sued the US federal government (defendant), claiming that the definitional amendments discriminated against close relatives in violation of the Due Process Clause of the Fifth Amendment because close relatives living together could not conform to the “purchase and prepare food separately” rule that was available to distant relatives or unrelated persons living together. The district court, applying heightened scrutiny, concluded that the definitional distinction was unconstitutional. The government appealed.