Graham v. Richardson

Brief Fact Summary. Aliens challenge state statutes that restrict and prevent their access to welfare benefits offered to citizens.

Synopsis of Rule of Law. A state cannot restrict or prevent aliens from receiving benefits offered to state citizens.

Facts. Aliens who were denied welfare benefits challenged an Arizona law allows welfare benefits to citizens, but imposes a residency requirement on aliens wanting to also receive welfare benefits. Aliens must reside in the state for 15 years before they can receive welfare benefits. The Aliens also challenge a Pennsylvania law that excludes aliens from certain state funded welfare benefits. The District Court ruled that both statutes violated equal protection.

Issue. Whether the Equal Protection Clause of the Fourteenth Amendment of the United States Constitution (Constitution) prevents a State from requiring a residency requirement to qualify for welfare benefits and from granting welfare benefits only to citizens of the state and not to aliens.

Held. Yes. A state’s intention to maintain welfare benefits for its own citizens is not a sufficient justification for restricting and preventing aliens access welfare benefits offered to the state’s citizens. Placing restrictions on aliens has historically been a power under the federal government, not state governments. Therefore, “making noncitizens ineligible for public assistance, and . . . restricting benefits to citizens and longtime resident aliens, violates the Equal Protection Clause.” The judgment is affirmed.

Discussion. “State law that restricts the eligibility of aliens for welfare benefits merely because of their alienage conflict with [ ] overriding national policies in an area constitutionally entrusted to the Federal Government . . . .”