Sosna v. Iowa
Headline: One-year divorce residency upheld, allowing Iowa to require new residents to wait before filing for divorce and delaying access to state courts for recent movers while the class-action challenge proceeds.
Holding: The Court held that Iowa’s one-year durational residency requirement for filing for divorce is constitutional, and class certification kept the challenge live so the Court could decide the merits.
- Requires new residents to wait one year before filing for divorce in Iowa.
- Allows States to use residency rules to limit quick forum-shopping for divorces.
- Class-action certification can keep short waiting-period challenges alive for others.
Summary
Background
A woman who moved to Iowa with her children sought a divorce soon after arriving, but an Iowa trial court dismissed her state petition because she had not lived in Iowa for a year as required by state law. Instead of appealing in state court, she filed a federal suit as a class action challenging the Iowa one-year residency rule for divorce. A three-judge federal court upheld the statute before the case reached the Supreme Court.
Reasoning
The Supreme Court first held the case was not moot because the certified class gave the unnamed new residents a continuing stake even though the named plaintiff later satisfied the year requirement and obtained a divorce elsewhere. On the merits, the majority explained that family-law and divorce regulation is primarily a state responsibility. The Court found Iowa’s one-year rule a reasonable way to show a petitioner’s real attachment to the State, to discourage “divorce mills,” and to reduce the risk that Iowa decrees would be successfully attacked in other States.
Real world impact
By upholding the law, the Court allowed Iowa and similarly situated States to keep a one-year residency barrier to filing for divorce. That means recent movers may have to wait before starting divorce proceedings in Iowa. The decision treats a durational residency rule as a constitutionally permissible form of state regulation rather than a forbidden penalty on travel.
Dissents or concurrances
Two dissents criticized the outcome: one Justice argued the case had become moot because the named plaintiff lost any personal stake, and two Justices argued the one-year rule unconstitutionally penalizes the right to travel and should have been invalidated.
Opinions in this case:
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