Graham v. Richardson
Headline: Court blocks state rules that deny welfare to resident aliens or require long U.S. residency, ruling those citizenship and durational bars unconstitutional and preventing states from excluding needy immigrants from benefits.
Holding: The Court held that state laws denying welfare benefits to resident aliens or conditioning benefits on long prior U.S. residence violate the Equal Protection Clause and conflict with federal immigration authority, so judgments were affirmed.
- Stops states from denying welfare to lawfully admitted resident aliens.
- Invalidates long durational residency rules (e.g., 15 years) for welfare eligibility.
- Requires states to treat eligible resident aliens the same as citizens for benefits.
Summary
Background
These cases involved state welfare rules in Arizona and Pennsylvania and three lawfully admitted resident aliens who were denied aid. Arizona required citizens or aliens with 15 years’ U.S. residence to get certain disability benefits. Pennsylvania excluded resident aliens from state-funded general assistance. The denied applicants sued, lower courts found the laws unconstitutional, and the states appealed to the Court.
Reasoning
The Court asked whether a State may refuse or limit welfare to people because they are not citizens or because they have not lived in the country long enough. It explained that treating resident aliens differently requires a very strong justification. The Court held that saving money or favoring citizens does not justify those distinctions, and that state rules also clash with the federal government’s authority over immigration. The Social Security Act language did not authorize the States to adopt these discriminatory rules. For those reasons, the Court affirmed the lower courts’ rulings.
Real world impact
The decision means states may not deny or condition welfare benefits solely because someone is an alien or lacks many years of U.S. residence. States must change eligibility rules that exclude otherwise qualified resident aliens. The ruling enforces equal treatment in state welfare programs and limits states from using immigration-related classifications to withhold assistance.
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