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Keywords

plaintiffstatutediscriminationclass actioncitizenshipliens
plaintiffdiscriminationclass actionliens

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Finch v. Commonwealth Health Ins. Connector

Facts

The plaintiffs are Massachusetts residents who either have been terminated from Commonwealth Care or denied eligibility solely as a result of their alienage. They brought a class action against the Connector alleging that exclusion from Commonwealth Care pursuant to an appropriation, St. 2009, c. 65, 31(a), violates their rights under the Massachusetts Constitution. The statute eliminated the plaintiffs' eligibility for Commonwealth Care by adopting the same eligibility standards applicable to federally funded public benefit programs. The court determined that 'national origin' and 'alienage' were distinct categories separate from citizenship.

The plaintiffs are Massachusetts residents who either have been terminated from Commonwealth Care or denied eligibility solely as a result of their alienage. They brought a class action against the Connector alleging that exclusion from Commonwealth Care pursuant to an appropriation, St. 2009, c. 65, 31(a), violates their rights under the Massachusetts Constitution.

Issue

Does the protection against discrimination on the basis of 'national origin,' as enumerated in art. 106 of the Amendments to the Massachusetts Constitution, include protection against discrimination on the basis of alienage?

Does the protection against discrimination on the basis of 'national origin,' as enumerated in art. 106 of the Amendments to the Massachusetts Constitution, include protection against discrimination on the basis of alienage?

Rule

The classifications set forth in art. 106 (sex, race, color, creed, or national origin) are subjected to the strictest judicial scrutiny. If a class is not addressed by art. 106, it does not follow that strict scrutiny is inappropriate but merely that there is no express constitutional mandate that such scrutiny be applied.

The classifications set forth in art. 106 [sex, race, color, creed, or national origin] . . . are subjected [***14] to the strictest judicial scrutiny.

Analysis

The court analyzed the distinction between 'national origin' and 'alienage,' concluding that discrimination against aliens is not inherently and necessarily discrimination against persons with national origins outside the United States. The court emphasized that the classifications in art. 106 do not include alienage, and thus, the plaintiffs' argument that discrimination on the basis of alienage is necessarily discrimination on the basis of national origin failed.

The court analyzed the distinction between 'national origin' and 'alienage,' concluding that discrimination against aliens is not inherently and necessarily discrimination against persons with national origins outside the United States.

Conclusion

The court answered the first three questions in the negative and did not need to reach the fourth question. The court concluded that the statute's exclusion of aliens from Commonwealth Care did not violate the Massachusetts Constitution.

The court answered the first three questions in the negative and did not need to reach the fourth question.

Who won?

The Commonwealth Health Insurance Connector Authority prevailed in the case because the court found that the exclusion of aliens from the Commonwealth Care Health Insurance Program did not violate the plaintiffs' constitutional rights.

The Commonwealth Health Insurance Connector Authority prevailed in the case because the court found that the exclusion of aliens from the Commonwealth Care Health Insurance Program did not violate the plaintiffs' constitutional rights.

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