Shapiro v. Thompson (1969) — Interstate Travel and Government Benefits

Case Identification Case name: Shapiro v. Thompson Court: Supreme Court of the United States Jurisdiction: Federal Year: 1969 Citation: 394 U.S. 618 (1969) Claim Presented Challengers contested state statutory provisions that required one year of continuous residence within the jurisdiction as a precondition for eligibility to receive public assistance benefits under the Aid to Families with Dependent Children program. The cases consolidated for review involved residency requirements enacted by Connecticut, Pennsylvania, and the District of Columbia. Appellees in each case were individuals who had recently moved to the jurisdiction and were denied welfare assistance solely because they had not satisfied the one-year residency requirement, despite otherwise meeting all eligibility criteria for benefits.

Authority Cited Equal Protection Clause of the Fourteenth Amendment. The Court recognized the constitutional right to travel interstate as a fundamental right protected under the Constitution.

Court's Analysis The Court evaluated the residency requirement as follows:

Nature of restriction: A one-year waiting period that denied welfare benefits to otherwise eligible residents who had not resided in the state for twelve consecutive months immediately preceding their application for assistance. The requirement applied regardless of the applicant's need or satisfaction of all other eligibility criteria. Constitutional interest: The right to travel freely between states, which the Court characterized as a fundamental constitutional right. The Court determined that the waiting period provisions operated to penalize the exercise of this right by denying welfare benefits to residents who had recently exercised their right to migrate to a new state. Standard applied: Strict scrutiny—the Court required the state to demonstrate a compelling governmental interest and that the classification was necessary to serve that interest. The Court stated that any classification that serves to penalize the exercise of a constitutional right must be shown to be necessary to promote a compelling governmental interest. The Court found the residency requirements created two classes of needy resident families indistinguishable from each other except that one class had resided in the jurisdiction for one year or more while the other had not. The Court examined and rejected the states' asserted justifications, including: (1) the fiscal interest in preserving the fiscal integrity of public assistance programs; (2) the administrative objective of providing an objective test of residency; (3) the goal of discouraging migration by indigents seeking higher welfare benefits; and (4) the interest in distinguishing between new and old residents on the basis that long-time residents had contributed to the community through taxes. The Court determined that the waiting period was not necessary to serve a compelling state interest and that less restrictive means were available to achieve legitimate state objectives. Brief quotation: The Court stated that the residency requirements had "the effect of imposing a penalty on the right to travel" and that "the purpose of deterring the in-migration of indigents cannot serve as justification for the classification created by the one-year waiting period, since that purpose is constitutionally impermissible." Disposition The statutory provisions imposing one-year residency requirements were invalidated. The judgments of the three-judge District Courts, which had declared the residency requirements unconstitutional, were affirmed.

Procedural Outcome The residency requirements in the challenged state statutes were struck down. The cases were resolved with the lower court decisions striking down the provisions being affirmed by the Supreme Court.

Archival Note This entry documents the judicial record in Shapiro v. Thompson as preserved in the official reports. The decision addressed constitutional limits on residency requirements for government benefits and clarified the relationship between interstate travel and equal protection principles.