Court: Supreme Court of the United States; June 14, 1971; Federal Supreme Court; Federal Appellate Court
State statutes in Arizona and Pennsylvania that restrict welfare benefits to resident aliens or those who have not resided in the U.S. for a specified duration violate the Equal Protection Clause and infringe on federal authority concerning alien residence. Specifically, Arizona's 15-year residency requirement lacks authorization under the Social Security Act. The case involves Carmen Richardson, a lawfully admitted resident alien who became permanently disabled but was denied welfare benefits solely due to her failure to meet the 15-year residency requirement. She filed a class action against the Commissioner of the State’s Department of Public Welfare, arguing that the residency requirements violate the Equal Protection Clause, infringe on her right to travel, conflict with the Social Security Act, and are preempted by federal law. A three-judge court granted her summary judgment, citing precedents that support her claims. The Commissioner of Public Welfare appealed the decision, which was stayed for all plaintiffs except Richardson.
Case No. 727 from Pennsylvania addresses a segment of the general assistance program that lacks federal funding, specifically focusing on the Pennsylvania Public Welfare Code, Pa. Stat. Ann. Tit. 62, § 432(2). This statute outlines eligibility for assistance, which includes needy individuals qualifying under federally supported programs and other needy U.S. citizens, with the latter group funded solely by the state.
Appellee Elsie Mary Jane Leger, a lawfully admitted resident alien from Scotland, has lived in Pennsylvania since 1965 and has been a taxpaying resident. After her and her husband's employment terminated due to illness in 1969, they sought public assistance. Mr. Leger qualified for state aid, but Mrs. Leger was denied assistance based on her alien status. The monthly aid awarded to Mr. Leger fell short of the minimum living standards required for a family of two in Philadelphia.
Mrs. Leger filed a class action lawsuit against state officials, seeking declaratory relief, an injunction against the enforcement of the alienage restriction, and back payments. A temporary restraining order was granted, allowing her to begin receiving assistance. Another plaintiff, Beryl Jervis, a Panamanian citizen, faced similar circumstances, being denied aid due to her alien status despite her long-term residency and tax contributions.
The court acknowledged that the denial of assistance to aliens causes significant hardship, leading to potential relocation to states with more inclusive assistance programs. Ultimately, a three-judge court, with one dissenting opinion, found that § 432(2) violated the Equal Protection Clause and prohibited its enforcement. The defendants appealed, arguing that states can legally prioritize U.S. citizens over aliens in welfare distribution without engaging in invidious discrimination.
The Fourteenth Amendment guarantees that no state may deprive any person of life, liberty, or property without due process and mandates equal protection under the law. The term "person" includes lawful resident aliens, who, alongside U.S. citizens, are entitled to equal protection. The Arizona and Pennsylvania statutes in question create distinctions between citizens and aliens regarding eligibility for assistance programs. Specifically, U.S. citizens in Arizona qualify for federally funded benefits without residency duration requirements, while aliens must reside in the U.S. for 15 years to qualify. In Pennsylvania, citizens can apply for state-supported assistance, but resident aliens are entirely excluded.
While states can classify individuals as long as there is a reasonable foundation for such classifications, distinctions based on alienage are treated with heightened scrutiny, as they affect a "discrete and insular" minority. The states argue that their restrictions stem from a public interest in prioritizing their citizens, but the court has historically invalidated such statutes unless necessary for protecting state interests. Previous cases have emphasized that discrimination against aliens cannot be justified by interests unrelated to public resources or welfare distribution.
Mr. Justice Cardozo's opinion highlights that while disqualifying aliens from state resources is a form of discrimination, it is not deemed unlawful as states may prioritize the welfare of their citizens over noncitizens. The court acknowledges the legitimacy of using state resources to benefit citizens, asserting that privileges can be contingent on citizenship. However, it cites several cases supporting the idea that states cannot impose arbitrary restrictions on noncitizens, especially regarding natural resources and property rights.
The landmark case Takahashi v. Fish and Game Commission raises questions about the validity of the special public-interest doctrine, as it ruled that California could not restrict fishing rights for aliens while allowing others to fish, emphasizing that all persons in the U.S. should have equal legal privileges under nondiscriminatory laws.
The text critiques the justification of limiting welfare benefits to citizens and long-term resident aliens based on the special public interest doctrine, which has been undermined by subsequent decisions that reject the notion that rights depend on whether a benefit is labeled a privilege or a right. The court recognizes a state's interest in fiscal integrity but asserts that this cannot justify discriminatory classifications among citizens and noncitizens. It emphasizes that both citizens and aliens are considered 'persons' under equal protection, and challenges the argument that the right to travel applies only to citizens, noting that the constitutional basis for this right is not confined to citizenship.
The Court has not determined if a specific right applies to aliens but indicates that strict scrutiny applies to classifications affecting fundamental rights, such as interstate movement, as established in Shapiro v. Thompson. The waiting-period provision in Shapiro, which denied welfare benefits to eligible applicants based solely on recent relocation, was unconstitutional as it penalized the exercise of a constitutional right without a compelling governmental interest. In contrast, current classifications affecting aliens are inherently suspect and thus also require strict scrutiny, regardless of whether a fundamental right is involved. The reliance on Dandridge v. Williams is deemed inappropriate since that case did not involve a fundamental right or a suspect criterion.
The Court agrees with prior findings that justifying discrimination against aliens based on expense limitations is unreasonable, as aliens contribute taxes and can reside and work in a state for extended periods. It concludes that state statutes denying welfare benefits to resident aliens or those without a significant duration of U.S. residency violate the Equal Protection Clause. Additionally, the regulation of aliens falls under federal jurisdiction, with Congress holding significant authority over immigration matters. While Congress has established criteria for excluding certain aliens, it has not placed restrictions on those who become indigent after entering the U.S.
All individuals within U.S. jurisdiction are entitled to equal protection under the law, as outlined in 42 U.S.C. 1981, which extends to both citizens and aliens. The Supreme Court has affirmed that aliens lawfully present have the right to enter and reside in any state with the same legal privileges as citizens, under nondiscriminatory laws. State laws that limit welfare benefits for aliens based solely on their status are in conflict with federal policies, as immigration regulation is a power reserved for the federal government. The Court has previously invalidated state laws, such as in Hines v. Davidowitz, that interfere with federal immigration regulations, emphasizing that states cannot add to or detract from Congress's established conditions regarding aliens. Furthermore, Congress has determined that lawfully admitted resident aliens who become public charges after entry cannot be deported and are entitled to the same state legal protections. State residency requirements for welfare effectively deter aliens from entering or residing in the state, which is inconsistent with federal authority. The ability to work is essential for aliens to reside where they choose, and denying them employment based on state laws infringes upon their federally protected rights, leading to potential segregation based on state discretion. This situation underscores that without access to public assistance, indigent aliens struggle to secure basic necessities, further complicating their ability to reside where they are legally allowed.
State laws imposing residency requirements for welfare benefits that discriminate against noncitizens infringe upon the exclusive federal authority to regulate immigration and are thus unconstitutional. Arizona's claim that its 15-year residency requirement is permissible under federal law relies on Section 1402(b) of the Social Security Act of 1935, which prohibits states from imposing citizenship requirements that exclude U.S. citizens from aid eligibility. However, this section does not explicitly authorize states to adopt residency restrictions for noncitizens. Legislative history indicates Congress's intent to prevent states from differentiating between native-born and naturalized citizens in welfare distribution, not to endorse discriminatory practices against noncitizens. While Congress holds significant power over immigration and naturalization, it cannot empower states to contravene the Equal Protection Clause. The interpretation of 1402(b) that would allow states to enact varying citizenship requirements for federally funded welfare programs would conflict with the constitutional mandate for uniformity in naturalization laws. Therefore, the Arizona residency requirement is not authorized by federal law.
The court affirms the judgments being appealed. Justice Harlan concurs with Parts III and IV of the Court's opinion and the overall judgment. The case concerns Arizona resident aliens who, due to not meeting the state's residency requirement, are denied welfare benefits for the disabled, aged, and blind. The eligibility criteria for assistance include U.S. citizens and specific non-citizens who declared intentions to become citizens during a defined period. The class represented by the appellees consists of approximately 65 to 70 cases annually, contrasting with about 585,000 individuals receiving categorical assistance in the Commonwealth. The Secretary of Health, Education, and Welfare has established regulations prohibiting states from imposing citizenship requirements that exclude eligible U.S. citizens from receiving aid. States may set conditions for non-citizens but must allow qualifying non-citizens who have resided in the U.S. for a specified duration. The court refrains from determining whether Congress could enact a nationwide residency requirement for aliens regarding federally funded welfare benefits.
