Facts
- Connecticut, Pennsylvania, and the District of Columbia denied public assistance (including AFDC or equivalents) to otherwise eligible applicants who had not resided in the jurisdiction for at least one year immediately before applying.
- Vivian Marie Thompson, a pregnant 19-year-old mother of one, moved from Massachusetts to Connecticut and was denied benefits solely because she had not met Connecticut’s one-year waiting period.
- Other applicants in the District of Columbia and Pennsylvania were similarly denied benefits solely due to failing the one-year durational residency requirement.
- The governments defended the waiting periods as protecting fiscal integrity, discouraging migration of indigent persons, distinguishing newer from longer-term residents based on past tax contributions, and serving administrative goals (budget planning, objective residency testing, fraud prevention, and encouraging workforce entry).
- Three-judge federal district courts in Connecticut, the District of Columbia, and Pennsylvania held the durational residency provisions unconstitutional, and the jurisdictions appealed directly to the Supreme Court.
Issues
- Whether one-year durational residency requirements for welfare benefits deny equal protection by treating similarly situated bona fide residents differently.
- Whether the classification burdens the constitutional right to interstate travel such that it must satisfy strict scrutiny.
- Whether congressional action (including provisions in the Social Security Act) could authorize or validate state durational residency requirements that otherwise violate the Constitution.
Decision
- The Supreme Court affirmed the district courts (6–3) and invalidated the one-year durational residency requirements.
- The Court held the laws created an unconstitutional classification among bona fide residents and penalized interstate travel.
- The asserted interests either could not be pursued constitutionally (deterring migration of indigents) or were not compelling, and the exclusions were not justified by narrowly tailored means.
- Congressional authorization, even if assumed, could not permit states to violate equal protection.
Legal Principles
- Interstate travel is a fundamental constitutional right; state action that penalizes it is subject to strict scrutiny and must be necessary to serve a compelling governmental interest.
- A state may not “fence out” indigent newcomers or deter their migration by withholding basic welfare benefits from otherwise eligible new residents.
- Equal protection forbids creating two classes of bona fide residents based solely on length of residence when the distinction denies essential benefits without a compelling justification.
- A state may not allocate benefits based on past tax contributions in a way that disadvantages new residents, because public services and benefits cannot be conditioned on prior contributions.
- Fiscal savings and administrative convenience, standing alone, are insufficient to justify a classification that burdens a fundamental right; less restrictive measures must be used when available.
- Congress cannot authorize states to engage in classifications that violate the Equal Protection Clause.
Conclusion
The Court held that one-year durational residency requirements for welfare assistance are unconstitutional because they penalize interstate travel and deny equal protection to otherwise eligible bona fide residents absent a compelling, narrowly tailored justification.