In the case of Knebel, Secretary of Agriculture v. Hein in 1976, the Supreme Court ruled on whether or not a family's eligibility for food stamps could be reduced due to their participation in another federal assistance program. The Heins were receiving both Aid to Families with Dependent Children (AFDC) and Low Income Home Energy Assistance Program (LIHEAP). The Department of Agriculture argued that LIHEAP benefits should count as income when calculating food stamp eligibility, which would reduce the amount they received. However, the court disagreed and held that energy assistance was intended to supplement other forms of aid rather than replace them. Therefore it should not be considered income for purposes of determining food stamp amounts under existing law at that time.

In the dissenting opinion for Knebel v. Hein, Justice Brennan disagreed with the majority's interpretation of Section 5(e) of the Food Stamp Act. He argued that it was not Congress' intention to exclude from eligibility those households where one or more members were on strike and unable to provide sufficient income. Instead, he believed that Congress intended to ensure all low-income households had access to a nutritionally adequate diet regardless of their employment status or other circumstances. Furthermore, he contended that excluding these families violated equal protection principles as it discriminated against them based on their decision to exercise their right to strike. In his view, this exclusion served no legitimate governmental purpose and only furthered economic hardship for already struggling families.