## Facts

- Carol Maureen Sosna moved from New York to Iowa in August 1972 and filed for divorce in Iowa state court about one month later.
- Iowa law required a divorce petitioner to have resided in Iowa for one year immediately before filing.
- The Iowa trial court dismissed Sosna’s divorce petition for lack of jurisdiction due to the unmet durational residency requirement.
- Sosna filed a federal Rule 23 class action against the State of Iowa and a state trial judge seeking declaratory and injunctive relief, alleging the one-year requirement violated due process and equal protection under the Fourteenth Amendment.
- A three-judge federal district court certified a class of persons who had lived in Iowa for less than one year and wished to file for divorce there, then upheld the statute.
- By the time of Supreme Court review, Sosna had lived in Iowa for more than one year, raising whether the case was moot despite the certified class.

## Issues

1. Whether a certified class action becomes moot when the named plaintiff’s individual claim is no longer live while the class members’ claims remain live.
2. Whether Iowa’s one-year durational residency requirement for filing a divorce action violates equal protection by burdening newer residents, including recent interstate migrants.
3. Whether the requirement violates due process by denying divorce access without permitting an individualized showing of bona fide residency.

## Decision

- The Supreme Court affirmed the judgment upholding Iowa’s durational residency requirement for divorce.
- The case was not moot because, after class certification, the class’s controversy remained live even if the named plaintiff’s individual claim no longer presented a live dispute.
- The Court held the one-year requirement did not violate equal protection because it imposed a delay rather than a permanent deprivation and was supported by legitimate state interests in divorce jurisdiction.
- The Court held the due process challenge failed because the statute represented permissible legislative line-drawing and did not permanently deny access to divorce courts.

## Legal Principles

- After a class is properly certified, the class acquires a legal status separate from the named plaintiff; the named plaintiff’s loss of a personal stake does not necessarily moot the case while class members retain live claims.
- A durational residency requirement may be constitutional when it creates a temporary waiting period rather than an absolute bar and when supported by substantial state interests.
- In the divorce context, states may justify durational residency rules based on interests in ensuring genuine connection to the forum, limiting interstate friction, and reducing the risk that decrees will be vulnerable to collateral attack or denied recognition elsewhere.
- Due process does not require an individualized exception to a fixed durational residency rule when the legislature has chosen an objective temporal requirement and the rule does not permanently deny access to the courts.

## Conclusion

The Court held that a certified class action challenging Iowa’s one-year divorce residency requirement remained justiciable even though the named plaintiff later satisfied the requirement, and it upheld the statute against equal protection and due process challenges because it imposed only a delay and served legitimate state interests in divorce jurisdiction and decree stability.


Sosna v. Iowa, 419 U.S. 393 (1975)