Facts
- Arizona limited certain welfare benefits to U.S. citizens or aliens who had lived in the United States for at least 15 years.
- Pennsylvania denied welfare benefits to aliens altogether while providing benefits to citizens.
- The challenged provisions operated within welfare programs funded under the federal Social Security Act.
- Welfare applicants and similarly situated resident aliens filed federal suits challenging the Arizona and Pennsylvania schemes.
- Three-judge federal district courts held the provisions unconstitutional and enjoined enforcement.
- The states appealed directly to the U.S. Supreme Court, which consolidated the cases.
Issues
- Whether the Equal Protection Clause permits a state to condition welfare benefits on U.S. citizenship or, for aliens, on a lengthy durational residency requirement.
- Whether state alienage-based welfare restrictions are invalid because they intrude on the federal government’s exclusive authority over immigration and alien status and conflict with federal welfare legislation.
Decision
- The Supreme Court affirmed the judgments invalidating both state schemes.
- The Court held that lawful resident aliens are “persons” protected by the Fourteenth Amendment’s Equal Protection Clause.
- The Court treated alienage classifications as inherently suspect and subject to strict scrutiny.
- The Court concluded that conserving welfare resources for citizens and related fiscal or administrative interests did not justify excluding resident aliens or imposing a durational requirement on them.
- Independently, the Court held the state provisions impermissibly encroached on exclusive federal authority over immigration and alien status and conflicted with the federal statutory scheme governing the welfare programs.
Legal Principles
- Lawful resident aliens are “persons” within the meaning of the Fourteenth Amendment and receive equal protection of the laws.
- State classifications based on alienage are suspect and generally trigger strict scrutiny; the state must show a compelling interest and necessary means.
- A state’s interest in preserving limited public benefits for citizens, budget management, or administrative convenience is insufficient to justify alienage-based exclusions under strict scrutiny.
- State rules that differentiate among lawful aliens in ways that interfere with federal control over alien entry, residence, and status may be invalid under federal supremacy and preemption principles.
- When states administer federally funded welfare programs, state-imposed alienage restrictions lacking federal authorization may be preempted.
Conclusion
The Court held that states may not deny welfare benefits to lawful resident aliens or condition such benefits on lengthy alien-only residency requirements, because alienage classifications are suspect under equal protection and because these restrictions can conflict with federal authority and federal welfare law.