Memorial Hospital v. Maricopa County
Headline: Court strikes down Arizona rule blocking recent county residents from free nonemergency medical care, ruling the one-year residency requirement unlawfully penalizes newcomers and limits access for indigent migrants.
Holding: The Court held that Arizona’s one-year county residency rule denying nonemergency free medical care to recent residents violates the Equal Protection Clause because it penalizes interstate migration and lacks a compelling state interest.
- Stops counties from denying nonemergency care to recent interstate migrants.
- Allows private hospitals to seek county reimbursement for indigent care.
- Makes durational residency rules subject to strict scrutiny when they burden travel.
Summary
Background
An indigent man moved from New Mexico to Phoenix and soon needed nonemergency hospital care. A private nonprofit community hospital treated him and asked Maricopa County to admit him to the public hospital and to reimburse $1,202.60. The County refused because he had not lived in the county for the prior 12 months under an Arizona law. Lower federal courts had declared the waiting rule unconstitutional, but the Arizona Supreme Court upheld it, prompting review by the U.S. Supreme Court.
Reasoning
The Court asked whether the one-year county residency rule denied equal protection by penalizing interstate migration, applying the framework of Shapiro v. Thompson. It concluded the rule burdened the right to travel and therefore required a compelling state interest. Arizona’s stated goals — protecting county finances, deterring an influx of indigents, administrative convenience, fraud prevention, and budget predictability — were not shown to be narrowly tailored or compelling. The Court stressed that nonemergency medical care for an indigent is a basic necessity and that less restrictive means were available.
Real world impact
The Supreme Court reversed the Arizona Supreme Court and invalidated the durational residency requirement as applied to nonemergency indigent medical care. Counties may no longer refuse nonemergency care to bona fide recent residents simply because they have not lived in the county for a year, and private hospitals may press claims for county reimbursement when eligible. The ruling forces counties to revise eligibility rules and consider narrower, constitutionally acceptable methods.
Dissents or concurrances
Justice Douglas (concurring in the result) emphasized the decision’s protection of the poor; Justice Rehnquist (dissenting) argued the rule was a reasonable way to allocate scarce local health resources and that its burden on travel was remote.
Opinions in this case:
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