Vlandis v. Kline

Background

Two women who applied to the University of Connecticut from other States became residents before or soon after starting school. Connecticut law (§126) permanently classified applicants as out‑of‑state if they had a legal address outside Connecticut when they applied or during the prior year. That irrebuttable classification barred any future challenge and made these students pay much higher tuition. A three‑judge District Court found the statute unconstitutional, ordered refunds, and enjoined enforcement; the State appealed to this Court.

Reasoning

The Court addressed whether a permanent, irrebuttable presumption of nonresidence violates the Fourteenth Amendment’s due process protection. Relying on prior rulings, the Court held that a rule which prevents a person from ever rebutting a factual presumption denies a fair opportunity to be heard. Connecticut’s stated goals—protecting subsidies for in‑state residents, favoring long‑time taxpayers, and administrative ease—did not justify permanently barring a student from proving genuine residency. The Court affirmed the lower court and said the State must allow students the chance to present evidence showing they are bona fide residents.

Real world impact

Students who move to a State or otherwise become residents after applying can no longer be forever barred from in‑state tuition without a chance to prove residency. States remain free to distinguish residents from nonresidents and may use reasonable criteria or durational requirements, but they must permit rebuttal procedures and may not rely on an absolute, permanent presumption. The District Court’s refund order for the women was consistent with that ruling.

Dissents or concurrances

Concurring Justices stressed disagreement about one‑year residency rules; dissenting Justices warned the decision hampers States’ control over university subsidies and criticized the Court’s doctrinal approach.