Grahmn v. Richardson Case Brief
Summary of Grahmn v. Richardson, 403 U.S. 365 (1971)
Facts: In AZ the law provided welfare recipients to be citizens, but not aliens unless they resided in US for 15 years. In PA law, if US citizens were unable to qualify for federal welfare funds, they could apply for state assistance, but resident aliens were excluded from receiving that assist.
Issue(s): Whether the EP Cl of the 14th prevents a state from conditioning welfare benefits on either: a) the recipient’s possession of U.S. citizenship; or b) if recipient is an alien, on his having resided in the U.S. for a certain number of years?
Holding: Yes. When a state statute denies welfare benefits to resident aliens and where another denied those benefits to aliens who have not resided in the US for a specified period, both violate the EP Cl of the 14th.
Procedure: In each of the consolidated cases, a three judge D Ct ruled that each statute violated the EP Cl. U.S. S. Ct. Affirmed both judgments.
Rule(s): 14th the term ‘person’ encompasses lawfully admitted aliens and citizens of the US, and entitles both to EP of the laws. Supremacy Cl. Art. IV sec. 1 cl.2
Rationale: “close” scrutiny.
Both AZ and PA statutes create two classes of needy persons, indistinguishable except for citizenship. Otherwise qualified US citizens living in AZ are entitled to federal funds w/o regard to the length of their residency in this country, but aliens must have lived here 15 years to qualify. In PA US citizens who cannot qualify for federal funds, may be eligible for state benefits, but resident aliens as a class are barred from receiving those benefits.
Typically states have broad discretion to legislate in the areas of social and economic welfare, but where classifications are inherently suspect, race, nationality, and alienage, then strict scrutiny applies. The power to apply state law exclusively to alien inhabitants is confined w/i narrow ltds.
A state’s desire to preserved limited economic resources to citizens is an inadequate justification in PA and AZ. There can be no “special public interest” in reserving tax revenue to citizens and excluding aliens when aliens have contributed equally to those revenues.
State laws that restrict the eligibility of aliens for welfare benefits solely b/c of their alienage conflict with the overriding national policies in an area reserved for the Federal Government. Restrictions that deny benefits to nonresidents or condition receipt on periods of residency, equate into the assertion of a right to deny entrance and a place of dwelling. Those restrictions are inconsistent with federal policies and are constitutionally impermissible.
Df’s A: (AZ/PA) States may favor US citizens over aliens in the distribution of benefits when consistent w/ EP Cl. This distinction does not involve invidious discrim’n b/c the state is not discriminating w/ respect to race or nationality. The restrictions on eligibility for public assistance are justified on the basis of “special public interest” favoring citizens over aliens in the distribution of limited resources.