Shapiro v. Thompson
Headline: Court struck down one-year residency rules that blocked newly arrived low-income residents from receiving welfare, making it easier for people who recently moved to get public assistance.
Holding: The Court held that statutes denying welfare to residents who lived in a State or D.C. for less than one year are unconstitutional because they unreasonably burden the right to travel and violate equal protection and due process.
- Stops states from denying welfare solely because someone moved recently.
- Allows newly arrived low-income residents to seek AFDC or similar aid.
- Prevents states from using residency rules to deter needy migration.
Summary
Background
Three separate cases challenged laws in Connecticut, the District of Columbia, and Pennsylvania that denied welfare benefits to people who had lived in the jurisdiction for less than one year. The applicants included a young unwed mother who moved to Connecticut, several women who returned to or moved into Washington, D.C., and mothers who moved to Pennsylvania. Each was denied Aid to Families with Dependent Children or similar help solely because they had not met the one-year residency requirement, and three-judge federal district courts ruled those laws unconstitutional.
Reasoning
The Court asked whether a rule that cuts off welfare for anyone who has lived in a State or D.C. for under a year can be justified. The majority held it cannot. The one-year rules were designed or operated to discourage needy people from moving in, which unconstitutionally burdens the basic right to travel. The statutes also treated all newcomers as if they came only to collect benefits, without any chance to rebut that assumption. The Court rejected fiscal, administrative, and fraud-prevention arguments as insufficient justification. It said the federal Social Security provision cited by the States did not validate the one-year rule, and Congress cannot authorize States to violate equal protection; the D.C. rule violated the Fifth Amendment’s due process protections.
Real world impact
The Court affirmed the district courts, so these specific one-year residency bars cannot be used to deny federally funded welfare or the D.C. benefits at issue. People who recently move to a State or to the District can no longer be excluded from these programs solely because they lack a year of prior residence. The decision limits state and local power to block needy newcomers from public assistance.
Dissents or concurrances
A concurring Justice stressed that the right to travel is a firmly established constitutional liberty. Dissenting Justices argued Congress could permit such residency rules and that the Court went too far in applying a strict test to these welfare laws.
Opinions in this case:
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