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Keywords

statuteburden of proof

statuteburden of proofnonprofitappellant

Related Cases

Memorial Hospital v. Maricopa County, 415 U.S. 250, 94 S.Ct. 1076, 39 L.Ed.2d 306

Facts

Henry Evaro, an indigent suffering from a chronic respiratory illness, moved from New Mexico to Maricopa County, Arizona. After a severe respiratory attack, he sought admission to the county hospital but was denied due to the Arizona statute requiring a year of residency for nonemergency medical care. Evaro's case was brought to court to determine whether Maricopa County was obligated to provide medical care or reimburse the private hospital that treated him.

Appellant Henry Evaro is an indigent suffering from a chronic asthmatic and bronchial illness. In early June 1971, Mr. Evaro moved from New Mexico to Phoenix in Maricopa County, Arizona. On July 8, 1971, Evaro had a severe respiratory attack and was sent by his attending physician to appellant Memorial Hospital, a nonprofit private community hospital.

Issue

Is the Arizona statute requiring a year of residency for indigents to receive nonemergency medical care at county expense unconstitutional under the Equal Protection Clause?

The constitutional question presented is whether this durational residence requirement is repugnant to the Equal Protection Clause as applied by this Court in Shapiro v. Thompson, 394 U.S. 618, 89 S.Ct. 1322, 22 L.Ed.2d 600 (1969).

Rule

The durational residency requirement must be justified by a compelling state interest, as it creates an invidious classification that impinges on the right of interstate travel.

Such a requirement, since it operates to penalize indigents for exercising their constitutional right of interstate migration, must be justified by a compelling state interest.

Analysis

The Court found that the Arizona statute's residency requirement penalizes indigents for exercising their constitutional right to migrate. The State failed to demonstrate a compelling interest that justified the residency requirement, as the asserted justifications, such as fiscal savings and administrative convenience, did not meet the necessary burden of proof. The Court emphasized that medical care is a basic necessity of life, and denying it based on residency status is unconstitutional.

Conclusion

The U.S. Supreme Court reversed the Arizona Supreme Court's decision, holding that the durational residency requirement is unconstitutional and remanded the case for further action consistent with this opinion.

The Arizona durational residence requirement for eligibility for nonemergency free medical care creates an ‘invidious classification’ that impinges on the right of interstate travel by denying newcomers ‘basic necessities of life.’

Who won?

Henry Evaro prevailed in the case because the U.S. Supreme Court found the residency requirement unconstitutional, thus affirming his right to receive medical care regardless of his residency duration.

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