403 U.S. 365 (1971)
Carmen Richardson, a lawfully admitted resident alien who emigrated from Mexico in 1956, was 64 years old when she instituted suit in July 1969 after becoming permanently and totally disabled.1 She had resided continuously in Arizona but was denied assistance to the permanently and totally disabled under Arizona Revised Statutes section 46-233 solely due to the requirement that aliens reside in the United States for fifteen years.2 Similar provisions conditioned old-age assistance and aid to the needy blind on citizenship or the same durational residency.3
Richardson brought a class action in the United States District Court for the District of Arizona against the Commissioner of the Department of Public Welfare seeking declaratory and injunctive relief as well as back payments.4 The three-judge court upheld Mrs. Richardson's motion for summary judgment on equal protection grounds.5 The Commissioner appealed. Probable jurisdiction was noted.
In the consolidated Pennsylvania case, Elsie Mary Jane Leger, who arrived from Scotland in 1965 and later entered a common-law marriage with a United States citizen, and Beryl Jervis, who arrived from Panama in 1968, both lawfully admitted resident aliens and taxpaying residents, were denied general assistance under Pennsylvania Public Welfare Code section 432(2) because they were not citizens.6 Both had become ill and unable to work, rendering them ineligible for federal programs, and Leger received a temporary restraining order allowing her to obtain benefits.7
The Pennsylvania plaintiffs filed class actions in the Eastern District of Pennsylvania against state welfare officials.8 After a stipulation that denial caused undue hardship and encouraged departure from the state, the three-judge court enjoined enforcement of the citizenship restriction.9 The defendants appealed, with probable jurisdiction noted, and the cases reached the Supreme Court for review.10
The Arizona program participated in federal categorical assistance under the Social Security Act, while the Pennsylvania general assistance was state-funded only.11
Whether the Equal Protection Clause of the Fourteenth Amendment prevents a State from conditioning welfare benefits upon the beneficiary's possession of United States citizenship?12
The Equal Protection Clause of the Fourteenth Amendment extends to lawfully admitted resident aliens.13 Classifications based on alienage are inherently suspect and subject to close judicial scrutiny.14 A state's asserted special public interest in preserving limited welfare resources for its own citizens fails to justify denying benefits to resident aliens, as the right-privilege distinction has been rejected and fiscal concerns cannot support invidious classifications.1516
Yes. The Pennsylvania statute at issue denied general assistance benefits to Elsie Mary Jane Leger and Beryl Jervis solely on the ground that they were not United States citizens, even though both women were lawfully admitted resident aliens who had resided continuously in the Commonwealth, paid taxes, and become unable to work through illness.17 The Arizona statute likewise created two classes of needy persons for APTD, old-age, and blind assistance that were indistinguishable except for citizenship or the fifteen-year national residency requirement imposed only on aliens.18 Under the established facts, these classifications triggered strict scrutiny because alienage constitutes a suspect criterion akin to race or nationality.19
The special public interest doctrine advanced by the states was rejected.20 Constitutional rights no longer turn on labeling a benefit a right or privilege.21 The interest in preserving fiscal integrity cannot justify invidious distinctions among persons within a state's jurisdiction, as the court had already held in the context of durational residency requirements for citizens.22
The Equal Protection Clause prevents a State from conditioning welfare benefits upon the beneficiary's possession of United States citizenship.23
Whether the Equal Protection Clause of the Fourteenth Amendment prevents a State from conditioning welfare benefits for an alien upon having resided in the United States for a specified number of years?24
The Equal Protection Clause of the Fourteenth Amendment extends to lawfully admitted resident aliens. Classifications based on alienage are inherently suspect and subject to close judicial scrutiny. A state's asserted special public interest in preserving limited welfare resources for its own citizens fails to justify conditioning benefits on a lengthy national residency requirement applicable only to aliens.25 The right-privilege distinction has been rejected.26 Fiscal concerns cannot support invidious classifications.
Yes. Carmen Richardson, a lawfully admitted resident alien who emigrated from Mexico in 1956 and had resided continuously in Arizona, was denied APTD benefits under Arizona Revised Statutes section 46-233 solely because she had not accumulated fifteen years of residence in the United States, despite meeting every other eligibility criterion after becoming permanently and totally disabled.27 Similar durational requirements applied to old-age assistance and aid to the needy blind.28 The established facts show that the classification operated on the suspect basis of alienage alone and therefore demanded strict scrutiny.29
Arizona's attempt to justify the requirement as a permissible means of conserving state resources for citizens was rejected.30 The special public interest rationale no longer sustains differential treatment once a benefit is characterized as a privilege rather than a right.31 Saving welfare costs cannot validate an otherwise invidious classification under the compelling-interest standard applied to suspect classes.32
The Equal Protection Clause prevents a State from conditioning welfare benefits for an alien upon having resided in the United States for a specified number of years.33
Whether state statutes that restrict welfare eligibility for aliens based on citizenship or durational residency conflict with federal authority over immigration and naturalization?34
Congress possesses broad power to regulate the admission, naturalization, and residence of aliens.35 Federal statutes provide that lawfully admitted aliens who become public charges for causes arising after entry are not subject to deportation.36 They are entitled to the full and equal benefit of all state laws for the security of persons and property.37 State laws that impose additional burdens on aliens by denying or conditioning welfare benefits on citizenship or long-term residency conflict with this uniform federal policy and are therefore constitutionally impermissible.38
Yes. The Arizona and Pennsylvania statutes restricted welfare eligibility for lawfully admitted resident aliens solely because of their alienage or failure to satisfy a fifteen-year national residency requirement.39 Under the established facts, these restrictions operated to discourage continued residence in the state and to deny indigent aliens the means to secure food, clothing, and shelter after they had entered the country and contributed through taxes.40 Federal law excludes only those aliens likely to become public charges at the time of entry and does not impose post-entry burdens on aliens who later become indigent.41
The state requirements therefore added auxiliary conditions on residence that conflicted with the comprehensive federal scheme governing immigration and naturalization, encroaching on an area of exclusive federal authority.42
State statutes that restrict welfare eligibility for aliens based on citizenship or durational residency conflict with federal authority over immigration and naturalization.43
Whether section 1402(b) of the Social Security Act authorizes Arizona's fifteen-year durational residency requirement for aliens seeking federally supported welfare benefits?44
Section 1402(b) of the Social Security Act directs the Secretary not to approve state plans that impose citizenship requirements excluding any United States citizen.45 It does not affirmatively authorize states to impose durational residency requirements applicable only to aliens.46 Any contrary construction would raise serious constitutional questions under the Equal Protection Clause and the uniformity requirement of the naturalization power.47
No. Arizona relied on section 1402(b) to defend its fifteen-year national residency requirement for aliens receiving APTD benefits under a federally assisted program.48 The established facts demonstrate that the provision, on its face and in light of its legislative history, merely prevents states from distinguishing between native-born and naturalized citizens.49 It contains no language commanding or permitting states to condition alien eligibility on lengthy prior residence.50 Construing the statute to authorize such discrimination would permit divergent state laws on citizenship requirements for federal welfare programs, violating the constitutional demand for a uniform rule of naturalization.51
Section 1402(b) of the Social Security Act does not authorize Arizona's fifteen-year durational residency requirement for aliens seeking federally supported welfare benefits.52