Caseflicks

Supreme Court of the United States • 1975

Sosna v. Iowa

419 U.S. 393 | 95 S. Ct. 553 | 42 L. Ed. 2d 532 | 1975 U.S. LEXIS 19 | 19 Fed. R. Serv. 2d 925

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Takeaway

In short, this case holds that a certified class action can survive the named plaintiff's mootness when short-lived claims would otherwise evade review, and that Iowa could require a one-year residence before allowing a newcomer to seek a divorce in its courts.

Background

Carol Sosna moved from New York to Iowa in August 1972 and, about a month later, petitioned an Iowa court to dissolve her marriage. Iowa law generally required a divorce petitioner to have been a state resident for the preceding year. The state court dismissed her petition because neither her husband nor she satisfied the statutory residency conditions.

Rather than appeal through Iowa's courts, Sosna filed a federal class action on behalf of Iowa residents who had lived in the State for less than one year and wished to seek a divorce or legal separation. A three-judge federal district court upheld the requirement. By the time the Supreme Court considered the appeal, Sosna had met the one-year requirement and had obtained a divorce in New York, raising a question whether the case had become moot.

Issues

Issue #1

Whether Sosna's class action became moot when she personally satisfied Iowa's one-year residency requirement and obtained a divorce elsewhere.

Holding

No. The certified class action remained a live controversy even though Sosna's individual claim had become moot.

Reasoning

At filing and at class certification, Sosna had a concrete injury: Iowa's statute prevented her from pursuing a divorce in Iowa. Once the District Court properly certified the class, the unnamed class members acquired a legal status distinct from Sosna's individual stake in the litigation.

The challenged requirement continued to bar other recently arrived Iowa residents from filing for divorce. Because no individual plaintiff would ordinarily remain subject to a one-year waiting period long enough to complete appellate review, the controversy was capable of recurring as to class members while evading review by any single challenger.

The Court relied on the rationale reflected in Dunn v. Blumstein: a representative class action may continue where the named plaintiff's personal claim has expired, provided a live controversy remains between the defendants and class members. Sosna was a member of the class and had a live claim when certification occurred, and the class's interests were adequately represented.

Issue #2

Whether Iowa's one-year durational residency requirement for filing for divorce unconstitutionally penalized the right to interstate travel or denied equal protection.

Holding

No. Iowa could constitutionally require one year of residence before its courts would exercise divorce jurisdiction.

Reasoning

The Court distinguished Shapiro v. Thompson, Dunn v. Blumstein, and Memorial Hospital v. Maricopa County. Those cases invalidated waiting periods that denied welfare, voting, or medical care on rationales of fiscal savings or administrative convenience. Iowa's rule did not permanently withhold divorce relief; it delayed access until the petitioner fulfilled the residency condition.

Divorce is an area of domestic relations traditionally regulated by the States. A divorce decree determines marital status and often resolves substantial questions involving property, child custody, and child support. Iowa could reasonably require a petitioner to demonstrate a meaningful attachment to the State before invoking its courts on matters of that consequence.

The one-year requirement furthered Iowa's legitimate interest in avoiding use of its courts as a divorce mill by people with only a transient connection to the State. It also helped support the reliability of Iowa divorce decrees against collateral challenges elsewhere, since divorce jurisdiction is generally grounded in domicile and other States may scrutinize an ex parte finding of domicile.

The Court therefore concluded that Iowa's interest in a genuine and enduring connection between a divorce petitioner and the State justified a result different from the right-to-travel cases involving welfare, voting, and medical benefits. The Constitution did not require Iowa to make divorce jurisdiction immediately available upon a newcomer's arrival.

Issue #3

Whether Iowa violated due process by refusing to allow a newly arrived resident to prove bona fide domicile through an individualized determination rather than by waiting one year.

Holding

No. The durational requirement did not create an unconstitutional irrebuttable presumption or deny meaningful access to divorce courts.

Reasoning

Vlandis v. Kline prohibited Connecticut from applying a permanent and irrebuttable presumption that certain students were nonresidents for tuition purposes. But Vlandis expressly left States free to use a reasonable durational-residency requirement as part of determining bona fide residence. Iowa required more than current physical presence and intent to remain; it required one year of residence as a jurisdictional policy choice.

Boddie v. Connecticut did not control because Boddie involved an absolute bar: indigent persons unable to pay filing fees were effectively excluded forever from the only forum that could dissolve their marriages. Iowa did not impose a permanent exclusion. Its rule delayed access to divorce court, and the Court held that delay constitutionally permissible in light of Iowa's substantial interests.

Dissents

Justice White

Reasoning

Justice White dissented, arguing that the case was moot, in Justice White's view, because Sosna had satisfied the residency requirement and already obtained a divorce in another State. She no longer had any concrete interest that would permit her to sue individually or serve as a class representative.

Justice White rejected the majority's conclusion that certification itself preserved a live Article III controversy. A class action still requires an identifiable named plaintiff with a continuing personal stake, not merely an attorney, an abstract legal issue, and unnamed individuals who may have claims.

He also doubted that the Court could retrospectively treat Sosna as an adequate representative after she ceased to belong to the class. At minimum, he would have remanded so the District Court could assess mootness, representation, and whether another class member should intervene.

Justice Marshall

Reasoning

Justice Marshall, joined by Justice Brennan, concluded that Iowa's rule penalized interstate travel because access to divorce is a matter of fundamental personal importance. The ability to end a marriage is closely connected to the fundamental right to marry, and a one-year exclusion burdened newcomers who sought to establish a new life in another State.

Under Shapiro, Dunn, and Memorial Hospital, he would have required Iowa to establish a compelling governmental interest and show that its restriction was necessary. He criticized the majority for replacing that established framework with an ad hoc balancing approach that gave undue deference to speculative state interests.

The distinction between a delay and a complete denial was unpersuasive. A person forced to remain married for a year loses opportunities to remarry and may remain trapped in a destructive relationship; the harm is not cured merely because a divorce may become available later.

Iowa's interests in preventing divorce tourism and protecting its decrees from collateral attack could be served through the less restrictive requirement of bona fide domicile—physical presence plus an intent to remain. A blanket one-year rule was both overinclusive, including cases in which both spouses participated, and underinclusive, because a year of residence could not prevent collateral attack if domicile had actually been found incorrectly.