## Facts

- Connecticut charged higher tuition and additional fees to students classified as nonresidents at its public university.
- State law and university rules created a conclusive residency rule tied to a student’s address history: certain students with an out-of-state legal address at application (married) or during the prior year (single) were classified as nonresidents.
- The classification was permanent for the duration of the student’s enrollment, regardless of later conduct or intent.
- Student plaintiffs alleged they became bona fide Connecticut domiciliaries after enrolling but were barred from presenting evidence to obtain in-state tuition.
- The students sued state and university officials in federal district court, claiming the permanent presumption violated the Fourteenth Amendment’s Due Process Clause.
- The district court held the presumption unconstitutional, and the state officials appealed.

## Issues

1. Whether due process permits a state to impose a permanent, irrebuttable presumption of nonresidency for tuition based solely on a student’s past out-of-state address, without any opportunity to prove bona fide in-state domicile.
2. Whether the state’s administrative and anti-fraud interests justify denying individualized residency determinations when alternative methods exist.

## Decision

- The Supreme Court affirmed the judgment invalidating the permanent, irrebuttable presumption.
- The Court held that due process does not allow Connecticut to deny students any opportunity to present evidence of bona fide residency for in-state tuition.
- The Court emphasized it did not question the general practice of charging higher tuition to nonresidents; the defect was the conclusive method of classification.
- Because the presumption was not universally true and the state had workable alternatives to assess domicile, the statute’s permanent bar on contrary proof was unconstitutional.

## Legal Principles

- Due process is violated when the government uses a permanent, conclusive presumption about an adjudicative fact that is not necessarily true and that forecloses a meaningful chance to prove the contrary.
- Administrative convenience and fraud prevention, though legitimate interests, do not justify eliminating individualized consideration where reasonable, less restrictive methods are available.
- A state may define and police residency for tuition purposes, including using evidentiary standards or time-based requirements, but it must allow affected individuals a fair opportunity to demonstrate bona fide domicile.

## Conclusion

Connecticut could not constitutionally freeze a student’s tuition residency status based on a past out-of-state address and permanently bar proof of later-established domicile; due process required a mechanism for students to present evidence of bona fide in-state residency.


Vlandis v. Kline, 412 U.S. 441 (1973)