The Lyng v. Payne case in 1985 revolved around the constitutionality of a provision within the Food Security Act of 1985, which required farmers to return any government-provided crop support payments if they planted crops on highly erodible land or converted wetlands into farmland. The Supreme Court ruled in favor of Richard E. Lyng, Secretary of Agriculture at that time, and upheld this provision as constitutional. The court stated that such requirements did not constitute an unconstitutional taking without just compensation under the Fifth Amendment because farmers voluntarily entered into these agreements with full knowledge about potential penalties for non-compliance. Furthermore, it was determined that there was no violation against due process rights since adequate notice and opportunity to be heard were provided before any penalties were imposed.

In the dissenting opinion for Lyng, Secretary of Agriculture, et al. v. Payne et al., Justice Brennan disagreed with the majority's decision to uphold a provision in the Food Stamp Act that denied benefits to households containing unrelated individuals. He argued that this provision violated equal protection principles by discriminating against non-traditional families without a rational basis. According to him, Congress' stated goal of preventing food stamp fraud did not justify such broad and arbitrary discrimination because there was no evidence showing higher rates of fraud among households with unrelated members compared to traditional families. Furthermore, he pointed out that other provisions in the law already addressed concerns about fraudulent claims more directly and effectively without resorting to discriminatory measures.