Califano v. Aznavorian
Headline: Court upholds federal rule denying SSI payments for any month a recipient spends entirely abroad, reversing the lower court and making it harder for traveling beneficiaries to keep those welfare payments.
Holding:
- Allows suspension of SSI payments for months spent entirely outside the United States.
- Requires 30 consecutive days in the U.S. to restore benefits after a long absence.
- Reverses lower-court relief that ordered some retroactive payments.
Summary
Background
Grace Aznavorian is an American citizen and a Supplemental Security Income (SSI) recipient who left the United States in July 1974 and stayed in Mexico through early September. The SSI law bars payment for any month a person is entirely outside the United States and treats someone gone 30 consecutive days as remaining outside until they return for 30 consecutive days. Aznavorian sued after losing two months of benefits; a federal district court certified a class and ordered relief for some absent recipients.
Reasoning
The Supreme Court addressed whether the benefit suspension unconstitutionally burdens international travel. The Court rejected that argument and applied the usual, deferential standard for welfare programs: a law is constitutional so long as it is not wholly irrational. The Court said the rule implements Congress’ choice to limit SSI to U.S. residents, that the 30-day rules are a rational way to check residency and administrability, and that an incidental effect on travel does not change the result.
Real world impact
Because the Court reversed, the Secretary may withhold SSI payments for months a recipient is fully abroad and may treat long absences as extending the ineligibility period until the person spends 30 straight days back in the United States. The Court did not reach, or need to decide, all questions about retroactive payments and other remedies after its constitutional ruling.
Dissents or concurrances
Justices Marshall and Brennan joined the judgment but warned that upholding welfare classifications still requires a meaningful review and that the standard of review should not be weakened when basic interests are involved.
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