Shapiro v. Thompson

Brief Fact Summary.

Appellees challenged the District of Columbia’s statute that denies welfare assistance to residents of the State or District who have not resided within their jurisdictions for at least one year immediately preceding their applications for such assistance.

Synopsis of Rule of Law.

The constitutional right to travel from one State to another occupies a position fundamental to the concept of our Federal Union and it is a right that has been firmly established and repeatedly recognized, though the right finds no explicit mention in the Constitution.

Facts.

District of Columbia has a statute that denies welfare assistance to residents of the State or District who have not resided within their jurisdictions for at least one year immediately preceding their applications for such assistance. Appellants try to justify the waiting-period requirement as a protective device to preserve the fiscal integrity of state public assistance programs. They asserted that people who require welfare assistance during their first year of residence in a State are likely to become continuing burdens on state welfare programs. They also argue that even if it is impermissible for a State to attempt to deter the entry of all indigents, the challenged classification may be justified as a permissible state attempt to discourage those indigents who would enter the State solely to obtain larger benefits.

Issue.

Does the District of Columbia’s statute that denies welfare assistance to residents of the State or District who have not resided within their jurisdictions for at least one year immediately preceding their applications for such assistance violate the Constitution?

Held.

Yes, the District Columbia’s statute is invalid even if it was adopted by Congress as an exercise of federal power because the Due Process Clause of the Fifth Amendment prohibits Congress from denying public assistance to poor persons otherwise eligible solely on the ground that they have not been residents of the District of Columbia for one year at the time their applications are filed.

Dissent.

Justice Warren and Harlan

Warren: Our cases require only that Congress have a rational basis for finding that a chosen regulatory scheme is necessary to further interstate commerce. A congressional finding that residence requirements allowed each State to concentrate its resources upon new and increased programs of rehabilitation ultimately resulting in an enhanced flow of commerce is rational.

Harlan: The “compelling interest” doctrine adopted by the Court constitutes an increasingly significant exception to the long-established rule that a statute does not deny equal protection if it is rationally related to a legitimate governmental objective. The majority’s decision reflects to an unusual degree the current notion that the Court possesses a peculiar wisdom.

Discussion.

While a State has a valid interest in preserving the fiscal integrity of its programs and may legitimately attempt to limit its expenditures for public assistance, a State may not accomplish such a purpose by invidious distinctions between classes of its citizens. Appellants must do more than show that denying welfare benefits to new residents saves money. The saving of welfare costs cannot justify an otherwise invidious classification. Appellants here do not use and have no need to use the one-year requirement for the governmental purposes suggested. Because the classification here touches on the fundamental right of interstate movement, its constitutionality must be judged by the stricter standard of whether it promotes a compelling state interest. Under this standard, the waiting-period requirement violates the Equal Protection Clause.