Mathews v. Diaz Case Brief

Summary of Mathews v. Diaz, 426 U.S. 67 (1976)

Facts: 3 resident aliens, lawfully admitted to the US less than five years ago were denied enrollment in Medicare supplemental medical insurance program. Two, were from Cuba, and remain under discretion of Atty Gen, the Third has been admitted as permanently.

Issue(s): Whether Congress can condition an alien’s eligibility for participation in federal medical insurance program on continuous residency in the US over a five year period, and admission for permanent residency?

Holding: No, both conditions are Const’l. The statutory classification does not deprive liberty or property w/o DP. Classifying the category of person who are not citizens into subcategories of US citizens and aliens by Fed Govt is a routine and normally legitimate part of business is justified.

Procedure: Following denial, all three brought an action challenging 42 U.S.C. §1395o(2). D Ct held the first condition Unconst’l, and that it could be severed from the second. U.S. S. Ct Reversed.

Rule(s): 5th and 14th Amendments protect every one of the millions of aliens w/i the US from deprivation of life, liberty, and property w/o DP.

Rationale: §1395o(2) grants eligibility to citizens 65 or over, but excludes aliens unless they have been admitted for permanent residency AND resided in the US for five years.

The fact that all persons, aliens and citizens alike, are protected by the DP Cl does not mean all aliens are entitled to enjoy all the advantages of citizenship or that they must be placed in a single homogenous legal classification. Legitimate distinctions may justify attributes and benefits for one class and not the other; i.e. P & Imm; Right 2 Vote; Rep’s must be citizens for 7 yrs; Senators 9 years; and President must be natural born.

Exclusion of aliens and reservation of power to deport has not counterpart pertaining to citizens of the US. Congress has the power to regulate aliens differently, but not invidiously. Providing some welfare benefits to citizens does not require like benefits to all aliens. Ex: overnight visitor, diplomats, unfriendly hostile, or illegal entrant. The decision to share a bounty w/ guests rests under Congress’ desire to characterize the relationship btwn alien and citizens.

Law governing the relationship btwn US and alien visitors implicate foreign power. Where Congress has not duty to provide all aliens w/ benefits, the party challenging the validity has the Bo’P to invalidate the line separating the classification btwn some aliens from others.

IF the issue were confined to a denial of benefits by state solely b/c alienage there is little if any basis for favoring citizens of another state over citizens of another country.

Pl’s A: (Aliens) Requiring that aliens be 1) admitted as permanent residents; and sustain 2) residency for a period of years deprives some aliens and not others liberty or property w/o DP

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