Facts
- Metri El Souri, a lawful permanent resident alien and recent immigrant from Lebanon, applied for Michigan General Assistance (GA) benefits for himself, his wife, and three children.
- The Michigan Department of Social Services (DSS) denied the application under an Assistance Payments Manual policy requiring that, for the first three years after an alien’s entry, a portion of the alien’s sponsor’s income and assets be treated as available to the alien.
- The policy treated sponsor resources as “deemable” to the alien without proof of actual contribution and applied even if the sponsor did not contribute or disclaimed responsibility.
- El Souri challenged the denial as an unconstitutional alienage-based classification.
- The trial court ruled for El Souri, and the Michigan Court of Appeals affirmed; DSS sought review in the Michigan Supreme Court.
Issues
- Whether DSS’s sponsor-deeming policy for GA eligibility creates a classification based on alienage.
- If so, whether the classification violates the Equal Protection Clause of the Fourteenth Amendment.
Decision
- The Michigan Supreme Court held that the policy expressly classified applicants based on alienage by imposing sponsor-deeming rules on aliens during the first three years after entry.
- The court applied strict scrutiny because state-created alienage classifications are suspect and GA eligibility is not within a political-function exception.
- The court rejected fiscal integrity and administrative convenience as compelling interests sufficient to justify discrimination against lawful resident aliens.
- The court concluded the policy was not narrowly tailored because it imputed sponsor income regardless of whether the alien actually received support.
- The court affirmed the judgment for El Souri, invalidating the policy as applied to the GA program.
Legal Principles
- A state welfare eligibility rule that singles out lawful resident aliens for different treatment creates an alienage-based classification.
- State alienage classifications are presumptively invalid and generally subject to strict scrutiny under the Equal Protection Clause.
- Cost savings and administrative efficiency, standing alone, are not compelling interests that justify discrimination against a suspect class.
- A deeming rule that treats third-party income as available “without proof of actual contribution” is not narrowly tailored when it disqualifies needy applicants based on resources they may never receive.
- Federal authority over immigration does not automatically authorize a state to impose alienage-based restrictions in a state-administered general welfare program.
Conclusion
Michigan’s GA sponsor-deeming policy unconstitutionally discriminated against lawful resident aliens by presuming sponsor resources were available without proof of actual support; the policy failed strict scrutiny and could not be used to deny benefits.