Lyng v. International Union, United Automobile, Aerospace, & Agricultural Implement Workers

485 U.S. 360, 108 S. Ct. 1184, 99 L. Ed. 2d 380, 1988 U.S. LEXIS 1448, 56 U.S.L.W. 4268, 127 L.R.R.M. (BNA) 2977
CourtSupreme Court of the United States
DecidedMarch 23, 1988
Docket86-1471
StatusPublished
Cited by286 cases

This text of 485 U.S. 360 (Lyng v. International Union, United Automobile, Aerospace, & Agricultural Implement Workers) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lyng v. International Union, United Automobile, Aerospace, & Agricultural Implement Workers, 485 U.S. 360, 108 S. Ct. 1184, 99 L. Ed. 2d 380, 1988 U.S. LEXIS 1448, 56 U.S.L.W. 4268, 127 L.R.R.M. (BNA) 2977 (1988).

Opinions

Justice White

delivered the opinion of the Court.

A 1981 amendment to the Food Stamp Act states that no household shall become eligible to participate in the food stamp program during the time that any member of the household is on strike or shall increase the allotment of food stamps that it was receiving already because the income of the striking member has decreased. We must decide whether this provision is valid under the First and the Fifth Amendments.

I

In the Omnibus Budget Reconciliation Act of 1981 (OBRA), Pub. L. 97-35, 95 Stat. 357, Congress enacted a package of budget cuts throughout the Federal Government. Among the measures contained in OBRA were more than a dozen specific changes in the food stamp program, id., §§ 101-117.1 One of them was the amendment at issue in [363]*363this case, § 109 of OBRA, which is set out in the margin.2 The Committee Reports estimated that this measure alone would save a total of about $165 million in fiscal years 1982, 1983, and 1984. H. R. Rep., at 12; S. Rep., at 63.

In 1984, two labor unions and several individual union members brought suit against the Secretary of Agriculture in District Court, contending that §109 is unconstitutional and requesting declaratory and injunctive relief. Plaintiffs moved for a preliminary injunction, and the Secretary moved to dismiss the complaint on the grounds that Congress’ action was well within its constitutional prerogatives. After a hearing, the District Court denied both motions. 648 F. Supp. 1234, 1241 (DC 1986) (Appendix).

Both sides conducted discovery and filed cross-motions for summary judgment. On November 14, 1986, the District Court granted plaintiffs’ motion for summary judgment and issued a declaratory judgment, holding the statute unconstitutional. 648 F. Supp. 1234. Specifically, the District Court found that the amendment to the Food Stamp Act was unconstitutional on three different grounds. First, it interferes or threatens to interfere with the First Amendment rights of the individual plaintiffs to associate with their families, with their unions, and with fellow union members, as [364]*364well as the reciprocal rights under the First Amendment of the union plaintiffs to their members’ association with them. Second, it interferes with strikers’ First Amendment right to express themselves about union matters free of coercion by the Government. Third, it violates the equal protection component of the Due Process Clause of the Fifth Amendment. As the basis for its conclusion on the equal protection claim, the District Court mentioned several somewhat related deficiencies in the amendment: it betrays an animus against an unpopular political minority, it irrationally treats strikers worse than individuals who quit a job, and it impermissibly directs the onus of the striker’s actions against the rest of his family. Id., at 1239-1241. The Secretary appealed the decision directly to this Court under 28 U. S. C. § 1252, and we noted probable jurisdiction. 481 U. S. 1036 (1987). We now reverse.

II

We deal first with the District Court’s holding that § 109 violates the associational and expressive rights of appellees under the First Amendment. These claimed constitutional infringements are also pressed as a basis for finding that appellees’ rights of “fundamental importance” have been burdened, thus requiring this Court to examine appellees’ equal protection claims under a heightened standard of review. Zablocki v. Redhail, 434 U. S. 374, 383 (1978). Since we conclude that the statute does not infringe either the associational or expressive rights of appellees, we must reject both parts of this analysis.

A

The challenge to the statute based on the associational rights asserted by appellees is foreclosed by the reasoning this Court adopted in Lyng v. Castillo, 477 U. S. 635 (1986). There we considered a constitutional challenge to the definition of “household” in the Food Stamp Act, 7 U. S. C. § 2012(i), which treats parents, siblings, and children who live together, but not more distant relatives or unrelated per[365]*365sons who do so, as a single household for purposes of defining eligibility for food stamps. Although the challenge in that case was brought solely on equal protection grounds, and not under the First Amendment, the Court was obliged to decide whether the statutory classification should be reviewed under a stricter standard than mere rational-basis review because it “ ‘directly and substantially’ interfere^] with family living arrangements and thereby burden[s] a fundamental right.” 477 U. S., at 638. The Court held that it did not, explaining that the definition of “household” does not “order or prevent any group of persons from dining together. Indeed, in the overwhelming majority of cases it probably has no effect at all. It is exceedingly unlikely that close relatives would choose to live apart simply to increase their allotment of food stamps, for the costs of separate housing would almost certainly exceed the incremental value of the additional stamps.” Ibid.; see also id., at 643 (Brennan, J-., dissenting) (stating that rational-basis review is applicable); ibid. (White, J., dissenting) (same).

The same rationale applies in this case. As was true of the provision at issue in Castillo, it is “exceedingly unlikely” that § 109 will “prevent any group of persons from dining together.” Id., at 638. Even if isolated instances can be found in which a striking individual may have left the other members of the household in order to increase their allotment of food stamps,3 “in the overwhelming majority of cases [the statute] probably has no effect at all.” Ibid. The statute certainly does not “order” any individuals not to dine to[366]*366gether; nor does it in any other way “ ‘directly and substantially’ interfere with family living arrangements.” Ibid.

The statute also does not infringe the associational rights of appellee individuals and their unions. We have recognized that “one of the foundations of our society is the right of individuals to combine with other persons in pursuit of a common goal by lawful means,” NAACP v. Claiborne Hardware Co., 458 U. S. 886, 933 (1982), and our recognition of this right encompasses the combination of individual workers together in order better to assert their lawful rights. See, e. g., Railroad Trainmen v. Virginia, 377 U. S. 1, 5-6 (1964). But in this case, the statute at issue does not “‘directly and substantially’ interfere” with appellees’ ability to associate for this purpose. Lyng, supra, at 638.4 It does not “order” appellees not to associate together for the purpose of conducting a strike, or for any other purpose, and it does not “prevent” them from associating together or burden their ability to do so in any significant manner.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Anderson v. Meneses
W.D. Washington, 2022
Rueda v. Yellen
D. Maryland, 2020
Espinoza v. Montana Dept. of Revenue
591 U.S. 464 (Supreme Court, 2020)
Fred Taylor v. City of Shreveport
798 F.3d 276 (Fifth Circuit, 2015)
Erik Autor v. Penny Pritzker
740 F.3d 176 (D.C. Circuit, 2014)
Dragovich v. United States Department of the Treasury
848 F. Supp. 2d 1091 (N.D. California, 2012)
James v. Washington Metropolitan Area Transit Authority
649 F. Supp. 2d 424 (D. Maryland, 2009)
Smith v. Atlanta Independent School District
633 F. Supp. 2d 1364 (N.D. Georgia, 2009)
Deen v. Egleston
601 F. Supp. 2d 1331 (S.D. Georgia, 2009)
United States v. Arzberger
592 F. Supp. 2d 590 (S.D. New York, 2008)
Freebery v. Coons
589 F. Supp. 2d 409 (D. Delaware, 2008)
Johnson v. Bredesen
579 F. Supp. 2d 1044 (M.D. Tennessee, 2008)
Rac v. Sha
174 P.3d 84 (Washington Supreme Court, 2008)
Chamber of Commerce of the United States v. Lockyer
463 F.3d 1076 (Ninth Circuit, 2006)
Woodford v. Ngo
548 U.S. 81 (Supreme Court, 2006)
The Players, Inc. v. City of New York
371 F. Supp. 2d 522 (S.D. New York, 2005)
NYC C.L.A.S.H., Inc. v. City of New York
315 F. Supp. 2d 461 (S.D. New York, 2004)
Hedgepeth v. Washington Metropolitan Area Transit
284 F. Supp. 2d 145 (District of Columbia, 2003)
City of Bremerton v. Widell
51 P.3d 733 (Washington Supreme Court, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
485 U.S. 360, 108 S. Ct. 1184, 99 L. Ed. 2d 380, 1988 U.S. LEXIS 1448, 56 U.S.L.W. 4268, 127 L.R.R.M. (BNA) 2977, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lyng-v-international-union-united-automobile-aerospace-agricultural-scotus-1988.