Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

statuteappealcitizenshipappellantappelleeliens
motionsummary judgmentcitizenshipappelleeliensmotion for summary judgment

Related Cases

Al Shimari v. CACI Premier Tech.
View Case »
Gallo-Alvarez v. Ashcroft
View Case »
Angulo-Dominguez v. Ashcroft
View Case »
I.A. v. Garland
View Case »
Sanchez v. State
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

Graham v. Richardson

Facts

Appellants, the States of Arizona and Pennsylvania, had statutes that conditioned welfare benefits on either the beneficiary's possession of United States citizenship or, if the beneficiary was an alien, on having resided in the U.S. for a specified number of years. Appellees, who were aliens denied benefits under these statutes, filed actions against the states. The district courts ruled that the statutes violated the Equal Protection Clause of the Fourteenth Amendment, leading to the appeal by the states.

Appellee Carmen Richardson, at the institution of this suit in July 1969, was 64 years of age. She is a lawfully admitted resident alien. She emigrated from Mexico in 1956 and since then has resided continuously in Arizona. She became permanently and totally disabled. She also met all other requirements for eligibility for APTD benefits except the 15-year residency specified for aliens by 46-233 (A)(1).

Issue

Whether the Equal Protection Clause of the Fourteenth Amendment prevents a state from conditioning welfare benefits on possession of United States citizenship or, if an alien, on a specified duration of residency in the U.S.

The issue here is whether the Equal Protection Clause of the Fourteenth Amendment prevents a State from conditioning welfare benefits either (a) upon the beneficiary's possession of United States citizenship, or (b) if the beneficiary is an alien, upon his having resided in this country for a specified number of years.

Rule

Classifications based on alienage are inherently suspect and subject to close judicial scrutiny under the Equal Protection Clause of the Fourteenth Amendment.

But the Court's decisions have established that classifications based on alienage, like those based on nationality or race, are inherently suspect and subject to close judicial scrutiny.

Analysis

The Court applied the rule by examining the statutes in question and determining that they created two classes of needy persons based solely on citizenship status. The Court emphasized that the states' justifications for these classifications did not meet the strict scrutiny standard required for such inherently suspect classifications.

Accordingly, it was said in Takahashi, 334 U.S., at 420, that 'the power of a state to apply its laws exclusively to its alien inhabitants as a class is confined within narrow limits.'

Conclusion

The Court affirmed the district courts' judgments, holding that the statutes violated the Equal Protection Clause by unjustly discriminating against resident aliens.

The Court affirmed the district courts' judgments.

Who won?

The appellees (aliens) prevailed because the Court found that the states' statutes violated the Equal Protection Clause by discriminating against noncitizens without sufficient justification.

The three-judge court upheld Mrs. Richardson's motion for summary judgment on equal protection grounds.

You must be