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Keywords

plaintiffstatuteinjunctionappealdiscrimination

statuteappealhearing

Related Cases

Saenz v. Roe, 526 U.S. 489, 119 S.Ct. 1518, 143 L.Ed.2d 689, 67 USLW 4291, 61 Soc.Sec.Rep.Serv. 75, 99 Cal. Daily Op. Serv. 3574, 1999 Daily Journal D.A.R. 4559, 1999 CJ C.A.R. 2812, 12 Fla. L. Weekly Fed. S 227

Facts

In 1992, California enacted a statute limiting welfare benefits for newly arrived residents to the amount they would have received in their previous state for the first year of residency. This statute was challenged by three California residents who had moved to the state to escape abusive situations, alleging that the statute would significantly reduce their welfare benefits. The District Court found that the statute created disparities in benefit levels and penalized the decision to migrate to California, leading to a preliminary injunction against its implementation.

In 1992, California enacted a statute limiting the maximum welfare benefits available to newly arrived residents. The scheme limits the amount payable to a family that has resided in the State for less than 12 months to the amount payable by the State of the family's prior residence.

Issue

Did the California statute imposing a durational residency requirement for TANF benefits violate the Fourteenth Amendment right to travel?

Rule

The right to travel includes the right to be treated equally in a new state of residence, and any law that discriminates against newly arrived citizens based on residency duration is subject to strict scrutiny under the Equal Protection Clause.

The right to travel embraces three different components: the right to enter and leave another State; the right to be treated as a welcome visitor while temporarily present in another State; and, for those travelers who elect to become permanent residents, the right to be treated like other citizens of that State.

Analysis

The court applied the rule by examining the discriminatory nature of California's statute, which treated new residents differently based solely on their length of residency and prior state of residence. The court concluded that the statute imposed a penalty on the right to travel without a compelling governmental interest, as California's interest in saving money did not justify the discrimination against new residents.

Since the right to travel embraces a citizen's right to be treated equally in her new State of residence, a discriminatory classification is itself a penalty.

Conclusion

The Supreme Court affirmed the Court of Appeals' decision, holding that the California statute violated the Fourteenth Amendment and that federal approval of durational residency requirements did not validate the statute's constitutionality.

Judgment of Court of Appeals affirmed.

Who won?

The plaintiffs prevailed in the case because the court found that the California statute unconstitutionally discriminated against new residents, violating their right to travel.

The District Court issued a temporary restraining order and, after a hearing, preliminarily enjoined implementation of the statute.

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