Shapiro v. Thompson Case Brief
Summary of Shapiro v. Thompson
Facts: Statute denies welfare to residents who haven’t resided within their jurisdictions for at least one year.
Procedural History: Federal court held the statute unconstitutional.
Issue: Does the statute discriminating on the basis of length of residency violate the EPC?
Holding: Yes, the statute violates the EPC.
Reasoning: Justifications proposed by D:
- the statute preserves the fiscal integrity of state welfare programs because those who require welfare assistance during their first year of residency are likely to be long-term welfare recipients
- but, the purpose of inhibiting migration by needy persons into the state is constitutionally impermissible
- all citizens are free to travel throughout the country uninhibited by statutes
- the statute discourages those indigents who would enter the state soley to obtain larger benefits
- same reasoning as above.
- Further, would you deny the mother admission to the state because she comes here solely for the purpose of finding better schools for her children?
- the statute benefits those who have made contributions to the community through payments of taxes
- but, this logically permits the state to deny new residents from schools
- there may be a permissible interest in limiting expenditures, but not through the use of distinctions between classes of citizens
- Four administrative objectives
- Facilitates budget prediction (unfounded)
- Serves as an administratively efficient rule of thumb for determining residency (no, the welfare agency already individually reviews files)
- Safeguard against fraudulent receipt of benefits (less drastic measures are available)
- Encourages new residents to join the labor force promptly (but then this should apply to long-term residents too)
The statute fails under the SS test because it doesn’t further a compelling state interest.
Warren dissent: The statute doesn’t burden travel because travel itself is not prohibited. There’s a compelling interest in providing adequate welfare system.
- Shouldn’t expand the “compelling interest” doctrine to apply to much more than racial classifications. Further, the majority says that it will apply the “compelling interest” doctrine to anything affecting a fundamental right. Well, pretty much anything can be considered a fundamental right. The exception threatens to swallow the standard equal protection rule.
- Since the state thinks that the residence requirement rationally furthers valid governmental objectives, I see no problem with it.