Zobel v. Williams

Citation. 457 U.S. 55, 102 S.Ct. 2309, 72 L.Ed.2d 672 (1982).

Brief Fact Summary.

Plaintiffs challenged dividend distribution law, which provided varying shares of income based on year state residency was established.

Synopsis of Rule of Law.

Creating a permanent subclass of residents requires a minimal equal protection analysis, meaning the state’s goal must be rationally related to a state’s legitimate interest.

Facts.

In 1967, Alaska discovered large oil reserves on state-owned land. Revenues were distributed under a dividend program which gave earnings directly to each citizen over 18. Each individual was entitled to one dividend unit for each year of residency subsequent to 1959, the first year of statehood.

Plaintiffs established residency in Alaska in 1978. They brought suit under the Equal Protection Clause of the 14th Amendment, arguing they were entitled to enjoy full rights of Alaska citizenship on the same terms as all other citizens of the state.

Issue.

Whether a law which distributed varying amounts of income based on residency length violates the equal protection of new state citizens.

Held.

Yes. A law which distributed varying amounts of income based on residency length violates the equal protection of new state citizens.

Dissent.

Justice Rehnquist

This is an economic regulation. The Court has long held state economic regulations are presumptively valid. It impedes no right to travel and settle in Alaska. If anything, it encourages immigration. The right to travel cases bear no relevance to the question before us.

Concurrence.

Justice Brennan

I agree and write separately only to emphasize the pervasive discrimination embodied in Alaska’s scheme.

Justice O’Connor

The scheme also violates Article IV’s Privileges and Immunities Clause. I reach the same conclusion as the Court.

Discussion.

The first two state objectives — creating a financial incentive for individuals to establish and maintain Alaska residence, and assuring prudent management of the funds — are not rationally related to the distinctions Alaska seeks to make between its residents. Additionally, the state’s objective that the fund will reward past contributions is not sufficient.

If the states can make the amount of a cash dividend depend on length of residence, what would preclude varying university tuition on a sliding scale or even limiting access to public facilities, student loans, or government contracts? It would divide citizens into expanding numbers of permanent classes, which would also be impermissible. Judgement reversed.