Takeaway
In short, this case made alienage a suspect classification: States generally may not deny public welfare benefits to lawfully admitted resident aliens merely to reserve resources for citizens, and they may not use welfare rules to undermine federal immigration policy.
The Court consolidated challenges to Arizona and Pennsylvania welfare laws that disadvantaged lawfully admitted resident aliens. Arizona denied federally supported assistance to otherwise eligible aliens unless they had lived in the United States for 15 years. Carmen Richardson, a Mexican national who had lawfully lived in Arizona since 1956, was denied disability benefits solely because she had not completed that period.
Pennsylvania provided state-funded general assistance to needy United States citizens who did not qualify for federal categorical programs, but excluded resident aliens altogether. Elsie Leger and Beryl Jervis, both lawfully admitted, taxpaying Pennsylvania residents, were denied aid solely because of their alienage after illness left them unable to work.
Three-judge federal district courts held both schemes unconstitutional under the Equal Protection Clause. The Arizona court granted summary judgment for Richardson, and the Pennsylvania court, over one judge's dissent, enjoined enforcement of its citizenship restriction. The Supreme Court affirmed both judgments.
Issue #1
Whether the Equal Protection Clause permits a State to deny welfare benefits to lawfully admitted resident aliens, or to condition their benefits on lengthy residence in the United States.
Holding
No. Alienage is an inherently suspect classification, and neither Arizona's 15-year national-residence requirement nor Pennsylvania's citizenship bar survived the required close judicial scrutiny.
Reasoning
The Fourteenth Amendment protects every “person” within a State's jurisdiction, including lawfully admitted resident aliens. Arizona and Pennsylvania created classes of needy people who were identical in every relevant respect except citizenship: citizens could receive the relevant assistance, while aliens either received none or had to satisfy a 15-year residence condition.
Although States ordinarily have broad latitude in economic and social-welfare classifications, classifications based on alienage are inherently suspect, like classifications based on race or nationality. Resident aliens are a discrete and insular minority, so laws directed at them as a class require close judicial scrutiny rather than ordinary rational-basis review.
The States' asserted interest in conserving limited welfare resources for citizens did not justify the discrimination. The Court rejected the older view that a State may reserve any governmental “privilege” for citizens; constitutional protection does not turn on whether a benefit is described as a right or a privilege. Saving money also cannot justify an otherwise invidious classification.
The Court distinguished Dandridge v. Williams, which involved a family-size welfare rule rather than a suspect classification or a burden on a fundamental right. It also found it unnecessary to decide whether aliens themselves possess a constitutional right to interstate travel. Unlike Shapiro v. Thompson, strict scrutiny here followed directly from the use of alienage as the classification.
The fiscal rationale was particularly weak because resident aliens may live, work, pay taxes, and contribute to a State's economy for many years. A State has no special claim to tax revenues that resident aliens have contributed on the same terms as citizens.
Issue #2
Whether the state welfare restrictions also impermissibly intruded on the Federal Government's exclusive authority over immigration and the residence of lawfully admitted aliens.
Holding
Yes. The restrictions conflicted with federal immigration policy and therefore were constitutionally impermissible.
Reasoning
The National Government has broad and exclusive authority to decide which aliens may enter the country, how long they may remain, and the conditions of their residence and naturalization. Congress had adopted a comprehensive immigration scheme that excluded aliens likely to become public charges at entry, but did not impose comparable penalties on aliens who became indigent because of causes arising after lawful admission.
Federal law broadly protected the equal legal rights of persons within the United States, including aliens. Under Takahashi and Hines, States may not add to, curtail, or interfere with the conditions Congress has imposed on the admission and residence of aliens.
Denying welfare to resident aliens, or conditioning it on long national residence, burdens their ability to enter or remain in a State. An indigent alien unable to obtain food, clothing, and shelter cannot realistically remain where the State withholds assistance solely because of alienage. These laws thus operated as an impermissible state-based restriction on aliens' entrance and abode.
Issue #3
Whether the Social Security Act authorized Arizona to impose a 15-year national-residence requirement on alien applicants for federally supported disability assistance.
Holding
No. The relevant federal provision did not authorize Arizona's restriction.
Reasoning
The statute instructed the federal Secretary not to approve a state plan that excluded a United States citizen because of a citizenship requirement. On its face, however, it did not affirmatively authorize States to exclude aliens or to impose durational-residence requirements on them.
The legislative history showed that Congress's principal concern was preventing discrimination between native-born and naturalized citizens. Earlier committee reports suggesting that States could assist only citizens reflected, at most, an understanding of then-existing law and did not clearly grant States power to discriminate against resident aliens.
Reading the statute to permit different state citizenship restrictions would raise serious constitutional problems. Congress cannot authorize States to violate equal protection, and a construction allowing divergent state rules concerning citizenship requirements would also be difficult to reconcile with Congress's constitutional power to establish a uniform rule of naturalization. The Court therefore construed the statute to avoid those constitutional doubts.