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Shapiro v. Thompson
Citations: 22 L. Ed. 2d 600; 89 S. Ct. 1322; 394 U.S. 618; 1969 U.S. LEXIS 3190Docket: 9
Court: Supreme Court of the United States; April 21, 1969; Federal Supreme Court; Federal Appellate Court
Mr. Justice Brennan delivered the Court's opinion affirming the judgments of three District Courts that deemed unconstitutional state and District of Columbia laws requiring one year of residency before granting welfare assistance. In the Connecticut case, Vivian Marie Thompson, a 19-year-old unwed mother, was denied Aid to Families with Dependent Children (AFDC) assistance due to her lack of one-year residency in Connecticut. The court found that this waiting-period requirement infringed on the right to travel and violated the Equal Protection Clause of the Fourteenth Amendment, as it served no legitimate purpose other than to limit state expenditures by discouraging new residents in need of assistance. In the District of Columbia cases, four appellees faced similar denials of welfare assistance due to not meeting the one-year residency requirement. Minnie Harrell, who moved from New York for family support while battling cancer, was denied AFDC. Appellee Barley, a long-time hospital resident, had her application for Aid to the Permanently and Totally Disabled denied because her hospital time was not counted toward residency. Appellee Brown's application for assistance for her children was only partially approved based on her previous residency in the District. The uniform rationale across the cases was the unconstitutional nature of the residency requirements, which were found to lack a valid justification. Legrant moved to Washington, D.C. in March 1967 with her two children after her mother’s death and applied for AFDC assistance in July 1967 but was denied due to not meeting a one-year residency requirement. This case, along with similar cases, was consolidated for trial, leading to a three-judge District Court ruling that the one-year requirement was unconstitutional, violating the Equal Protection Clause of the Fifth Amendment. In another case, Smith and Foster also faced denial of AFDC aid in Pennsylvania on the same residency ground. Smith relocated from Delaware to Pennsylvania, while Foster returned to Pennsylvania after living in South Carolina. Both cases were also declared unconstitutional by a three-judge court, which found the waiting-period requirement lacked a rational basis and was intended to deter indigent individuals from moving into the state. The court highlighted that the waiting-period requirement unjustly distinguished between two classes of needy families based solely on their duration of residence, thereby denying equal protection. The appellants argued that the requirement aimed to protect state welfare programs from an influx of newcomers, but the court found that this justification did not meet constitutional standards, as it promoted discrimination against new residents in need of assistance. Sponsors of federal legislation aimed at removing residence requirements for welfare benefits face opposition from state and local welfare agency representatives. They express concerns that such removal would lead to an influx of individuals seeking generous benefits from states. For example, Connecticut's legislation argues against unlimited migration, fearing economic strain from newcomers seeking assistance. Similarly, Pennsylvania's Attorney General emphasized the need for a strict one-year requirement to prevent attracting dependents from other states. In legal challenges, the constitutionality of waiting periods has been defended as a means to limit this influx. However, the court recognizes that while a one-year waiting period may discourage migration, it is constitutionally impermissible to inhibit the movement of needy individuals. The right to travel freely among states is a fundamental aspect of the Federal Union, as established by historical court cases and affirmed by the notion that such freedom is a necessary element of citizenship. Therefore, deterring indigent migration cannot justify the waiting period imposed by states, as it violates constitutional principles. A law is unconstitutional if its sole purpose is to deter individuals from exercising their constitutional rights by imposing penalties. The statutes in question, aimed at discouraging indigents who might enter a state solely for enhanced welfare benefits, are overly broad and indiscriminately classify all newcomers, disregarding their actual intentions. This leads to a presumption that all applicants for assistance in their first year of residency are solely motivated by the desire for higher benefits, a presumption unsupported by factual evidence. Furthermore, the state cannot differentiate between indigents based on their motivations, as this implies that those seeking better welfare benefits are less deserving than others. The argument that long-term residents contribute more to the community financially than recent arrivals is flawed, especially given that many denied assistance had long-term residency. Such reasoning could unjustly restrict access to public services based on residency duration, which violates the Equal Protection Clause. While states can seek to maintain fiscal responsibility, they cannot do so through discriminatory practices. Simply saving costs does not justify a classification that unfairly targets new residents. Ultimately, neither the aim to deter indigents from migrating nor to limit benefits to those deemed contributive is constitutionally acceptable. Appellants argue that the one-year waiting-period requirement for welfare benefits serves four administrative objectives: facilitating welfare budget planning, providing an objective residency test, minimizing fraudulent claims across jurisdictions, and encouraging new residents to enter the labor force. However, the court rejects the notion that merely demonstrating a rational relationship between the waiting period and these objectives is sufficient for justification. The waiting period penalizes individuals for exercising their constitutional right to relocate, and any classification that does so must be necessary to promote a compelling governmental interest to avoid being deemed unconstitutional. The court finds no evidence that the waiting period contributes to welfare budget predictability, noting that states do not collect data on new residents or require prior notice of welfare needs, making it impossible to accurately predict assistance demands. Additionally, temporary and full assistance is provided to some new residents under reciprocal agreements, further undermining the relevance of the one-year requirement for budget planning. The testimony from Pennsylvania's Bureau of Assistance indicates that the agency has accurately estimated costs without relying on the one-year waiting rule. Furthermore, the waiting-period requirement is not an efficient measure for determining residency, as residency and waiting-period requirements are separate processes. Welfare authorities conduct thorough investigations into applicants’ circumstances to determine residency and can employ less drastic measures to prevent fraudulent claims. Thus, the one-year waiting period lacks justification based on the claimed administrative objectives. A state has a legitimate interest in preventing fraud among welfare applicants, but current investigative practices involve inquiries that are relevant to this issue. Cooperation between state welfare departments is common; for instance, the District of Columbia aids its former residents moving to states with waiting periods by requesting necessary information from the new welfare authorities to avoid double payments. It is deemed unreasonable to impose a one-year waiting period on all indigent newcomers when simpler methods, like a letter or phone call, could prevent double payments. While Pennsylvania argues that the waiting period encourages new residents to enter the labor force, this rationale would equally apply to long-term residents, which does not justify the restriction. The classification of welfare applicants by residency duration appears irrational and unconstitutional under traditional equal protection tests. Given the fundamental right of interstate movement, the waiting period's constitutionality should be assessed under a stricter standard that demands a compelling state interest, which it fails to meet, thus violating the Equal Protection Clause. Connecticut and Pennsylvania contend that the challenge is invalid because Congress allowed such requirements within the jointly funded Aid to Families with Dependent Children (AFDC) program. However, Section 402(b) of the Social Security Act does not endorse a one-year residency requirement; it merely prevents the Secretary from disapproving plans with such requirements. Legislative history indicates that Congress aimed to mitigate hardships from lengthy residence requirements, not to endorse them. Prior to the Act, many states enforced residency requirements of two years or more, prompting Congress to act against these restrictive policies. The objective of 402 (b) is to promote a liberal residence requirement for states participating in the Aid to Families with Dependent Children (AFDC) program, as indicated in the House and Senate Committee Reports. There is no support in the debates or reports suggesting that 402 (b) was meant to encourage state participation; rather, discussions around waiting-period requirements highlighted that participation relies on states repealing or significantly revising restrictive statutes. The assertion that Congress could compel 41 states to amend their laws contradicts the goal of cooperation. Even if a one-year waiting period were permissible, the constitutionality issue arises from state legislation, not 402 (b) itself, which is non-restrictive. Any argument regarding the constitutionality of 402 (b) would suggest that its allowance of a waiting period could be unconstitutional, as Congress cannot authorize states to contravene the Equal Protection Clause. Additionally, the waiting-period requirement in the District of Columbia Code is deemed unconstitutional as it discriminates against individuals based solely on residency duration, violating the Due Process Clause of the Fifth Amendment. The judgments in the related cases are affirmed, asserting that Congress cannot deny public assistance to eligible individuals based solely on their residency status. The AFDC program, established by the Social Security Act of 1935, provides federal funding for state assistance plans that comply with specified criteria. An appellee applied for Aid to the Permanently and Totally Disabled, a program funded by both state and federal resources (42 U.S.C. §§ 1351-1355). Connecticut law (Conn. Gen. Stat. Rev. § 17-2d, now § 17-2c) stipulates that individuals arriving in the state without visible means of support are eligible only for temporary aid if they apply for assistance within one year of arrival. Exceptions exist for those with bona fide job offers or who are self-supporting for three months post-arrival. The D.C. Code (D.C. Code Ann. § 3-203) allows public assistance for individuals who have resided in the District for one year before applying or were born to parents meeting residency requirements. In Ex parte Cogdell, the Supreme Court addressed whether a three-judge court is needed when challenging the constitutionality of a Congressional Act concerning the District of Columbia. Although this issue remains unresolved, the precedent set in Berman v. Parker shows that three-judge courts have adjudicated similar cases. Pennsylvania law (Pa. Stat. Tit. 62 § 432(6)) requires applicants for public assistance to have resided in the state for at least one year or meet specific conditions related to residency. Transients may receive assistance under established departmental standards. The argument that public assistance constitutes a 'privilege' rather than a 'right' does not suffice to address constitutional challenges, as indicated in Sherbert v. Verner. The waiting-period requirement has historical roots in English laws and practices from the 17th century, particularly the English Law of Settlement and Removal of 1662, which aimed to manage the influx of the poor to communities with more generous welfare systems. This law, along with the Elizabethan Poor Law of 1601, influenced similar practices in the American Colonies, where newcomers at risk of becoming public charges could be 'warned out' or transferred to other localities. Initially, welfare funding was sourced from local taxes, leading to disputes over responsibility among localities within a state. However, as states and, subsequently, federal governments took on greater responsibility, these disputes evolved into interstate issues. Key Supreme Court cases, including Corfield v. Coryell and Edwards v. California, have cited the Privileges and Immunities Clause and the Commerce Clause in addressing the right to travel and welfare access across state lines. Notably, the rationale for contribution-based restrictions on welfare, as seen in cases like Rinaldi v. Yeager, was deemed insufficient, especially in the context of children barred from benefits regardless of parental residency. Furthermore, both Connecticut and Pennsylvania have entered into interstate compacts to eliminate the waiting-period requirement for individuals from participating states, recognizing the unreliability of advance welfare registration. In Pennsylvania, the one-year waiting-period requirement for public assistance is waived under reciprocal agreements, although the residency requirement remains intact. Residency is defined as living in an established place of abode with the intent to remain, allowing individuals with a bona fide job offer or sufficient self-support for three months to bypass the waiting period. The Department of Health, Education, and Welfare (HEW) distinguishes between residency and duration of residence, proposing a declaration system for eligibility that relies on the applicant's statements rather than extensive individual investigations. This shift indicates a lack of concern regarding the one-year requirement as a fraud prevention measure, as seen in reciprocal agreements with other states. Legal standards regarding equal protection suggest that a classification is only unconstitutional if it lacks a reasonable basis, as established in cases like Lindsley v. Natural Carbonic Gas Co. and Flemming v. Nestor. The document notes that as of 1964, eleven jurisdictions had no residence requirement for Aid to Families with Dependent Children (AFDC) assistance, reflecting a push for greater freedom of movement articulated by Congress, particularly in the context of social security legislation. Additionally, the text references historical discussions within Congress about the constitutionality of various provisions of the Social Security Act, with no specific mention of the one-year waiting period's constitutionality.