Brief Fact Summary. Appellant moved from New York to Iowa and one month later brought suit for divorce in Iowa. Appellant’s husband challenged the jurisdiction of the Iowa court.
Synopsis of Rule of Law. A durational residency requirement is constitutional in that appellant was not permanently foreclosed from obtaining a divorce and the State’s interests in the requirement are legitimate.
Is the Statute unconstitutional because it establishes two classes of persons and discriminates against those who have recently exercised their right to travel to Iowa?
Is the Statute unconstitutional because it denies a litigant the opportunity to make an individualized showing of bona fide residence and therefore denies such residents access to the only method of legally dissolving their marriage?
Held. The Statute passes constitutional muster under both inquiries.
Previous precedent has invalidated durational residency requirements in areas such as qualification for welfare payments, voting, and medical care. However, none of these cases suggested that the States could never impose durational residency requirements. Appellant was not irretrievable foreclosed from obtaining some part of what she sought. Additionally, Iowa’s requirement may be reasonably justified on grounds other than the purely budgetary or administrative considerations claimed in the previous precedent. Such a requirement recognizes that both spouses are interested in the proceedings, avoids officious intermeddling in matters in which another State has a paramount interest, and minimizes the susceptibility of its own divorce decrees to collateral attack.
Furthermore, the failure to provide an individualized determination of residency does not violate the Due Process Clause. Such a determination would be fruitless, as Iowa requires not merely domicile, but residence in the State for a year. Appellant’s claim is not total deprivation of a divorce decree, which has been ruled unconstitutional, but only delay.
If none of the named plaintiffs purporting to represent a class establishes the requisite of a case or controversy with the defendants, none may seek relief on behalf of himself or any other member of the class.View Full Point of Law