419 U.S. 393 (1975)
Carol Sosna married Michael Sosna on September 5, 1964, in Michigan.1 They lived together in New York between October 1967 and August 1971, after which they separated but continued to reside there.2 In August 1972 Sosna moved to Iowa with her three children.3 The following month she petitioned the District Court of Jackson County, Iowa, for dissolution of her marriage.4
Michael Sosna was personally served when he visited Iowa and made a special appearance to contest jurisdiction.5 The Iowa court dismissed the petition for lack of jurisdiction under Iowa Code § 598.6 because Sosna had not resided in the state for one year preceding the filing.6
Instead of appealing, Sosna filed a complaint in the United States District Court for the Northern District of Iowa seeking injunctive and declaratory relief on constitutional grounds.7 A three-judge court was convened pursuant to 28 U.S.C. §§ 2281 and 2284.8 While the federal action was pending, the Iowa Supreme Court decided In re Marriage of Williams, 217 N.W.2d 202 (1974), and upheld the statute's constitutionality.9 The three-judge court upheld the residency requirement.10 This Court noted probable jurisdiction.11 During the appeal Sosna obtained a divorce in New York, though custody and support issues remained unresolved from the Iowa proceeding.12 She returned to Iowa to prosecute the appeal.13
Sosna sought class certification under Fed. R. Civ. P. 23 to represent Iowa residents who had lived in the state less than one year and wished to initiate divorce actions but were barred by the residency requirement.14 The parties stipulated that numerous people were similarly situated, joinder was impracticable, her claims were representative, and she would adequately protect class interests.15 The district court approved the stipulation in a pretrial order.16
Whether the one-year durational residency requirement for divorce under Iowa Code § 598.6 violates the Equal Protection Clause of the Fourteenth Amendment?17
A durational residency requirement for divorce does not create two classes of persons with different rights.18 It merely imposes a temporary barrier on those seeking to establish Iowa residency.19 The State's interests in ensuring genuine attachment to the State and insulating its decrees from collateral attack supply a rational basis.20 This distinguishes the requirement from those invalidated in Shapiro v. Thompson, Dunn v. Blumstein, and Memorial Hospital v. Maricopa County.21
No. After residing in Iowa for three months, Carol Sosna filed her petition in Jackson County District Court, triggering dismissal under Iowa Code § 598.6 for failure to meet the one-year threshold.22 The requirement applies uniformly to all who have not yet accumulated twelve months of residence.23 It does not permanently foreclose access, unlike the total deprivations in the welfare, voting, and medical-care cases.24 Iowa's interest in confirming that petitioners possess the modicum of attachment necessary to invoke its divorce jurisdiction, together with its interest in minimizing successful collateral attacks on its decrees under Williams v. North Carolina, supplies the requisite rational basis.25
The one-year durational residency requirement does not violate the Equal Protection Clause.26
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Joined by Justice Brennan
Justice Marshall dissented on the ground that the right to obtain a divorce is of fundamental importance comparable to voting and welfare.27 Any classification penalizing the exercise of the right to travel must be justified by a compelling state interest rather than mere rational basis.28 He argued that Iowa's asserted interests in attachment and decree integrity could be served by a simple domicile test without the rigid one-year barrier.29
The majority's ad hoc balancing improperly departed from the strict scrutiny applied in Shapiro, Dunn, and Maricopa County.30 He would have reversed the district court judgment.31
Whether the one-year durational residency requirement for divorce under Iowa Code § 598.6 violates the Due Process Clause of the Fourteenth Amendment?32
A durational residency requirement that merely delays rather than totally denies access to divorce courts does not violate due process.33 Boddie v. Connecticut is distinguishable because it involved permanent exclusion based on inability to pay fees.34 Here the same delay would occur in any state with a comparable statute.35
No. Sosna's petition was dismissed after three months of residence, yet she could have obtained the identical adjudication once the statutory period elapsed.36 The three-judge court correctly held that the delay is one of degree, not kind.37 Iowa's requirement of residence plus good-faith maintenance for one year does not arbitrarily foreclose the opportunity to dissolve a marriage.38 Unlike the filing-fee barrier in Boddie, the Iowa statute imposes a temporary, uniformly applied condition that the State may constitutionally attach to the exercise of its divorce jurisdiction.39
The one-year durational residency requirement does not violate the Due Process Clause.40
Whether the federal district court should have abstained from deciding the request for injunctive relief after the Iowa Supreme Court decided In re Marriage of Williams?41
When a state supreme court decision authoritatively construes a statute in a manner that significantly alters the nature of the federal constitutional claim, abstention under Railroad Commission v. Pullman Co. is appropriate.42
Yes. While the three-judge court was considering Sosna's complaint, the Iowa Supreme Court in In re Marriage of Williams held that the one-year requirement is a jurisdictional prerequisite and a legitimate regulation of access to divorce courts.43 That authoritative construction transformed the federal claim from one attacking a classification creating permanent classes into one attacking a temporary barrier.44 Abstention under Railroad Commission v. Pullman Co. was therefore appropriate for the injunctive request, and the district court correctly abstained on that ground.45
The district court properly abstained from ruling on the request for injunctive relief.46
Whether this Court has jurisdiction to review the district court's denial of declaratory relief?47
Yes. The three-judge court reached and rejected Sosna's request for a declaration that Iowa Code § 598.6 is unconstitutional.50 That denial presents a live controversy independent of the abstained injunctive claim.51 This Court may review the declaratory judgment ruling.52 The subsequent Williams decision did not divest the Court of that jurisdiction.53
This Court has jurisdiction to review the denial of declaratory relief.54
Whether the appeal is moot because the named plaintiff obtained a divorce in New York after the district court judgment and later satisfied Iowa's residency requirement?55
In a properly certified class action, the class acquires a legal status separate from the named plaintiff.56 When the controversy remains live for unnamed class members and the issue is capable of repetition yet evading review, the case does not become moot merely because the named plaintiff's personal stake has ended.57
No. The district court certified the class of Iowa residents residing less than one year who wished to file for divorce before Sosna's personal claim became moot.58 The parties stipulated that numerous individuals were in the identical situation, joinder was impracticable, and Sosna would adequately represent the class.59 Although Sosna later obtained a New York divorce and satisfied the Iowa residency period, the controversy continues for other class members.60 They will repeatedly face the same barrier before any single challenger can obtain full appellate review.61
The appeal is not moot.62
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Justice White dissented on the ground that once the named plaintiff's claim became moot through satisfaction of the residency requirement and procurement of a New York divorce, no live adverse party remained before the Court.63 He argued that certification cannot substitute for a plaintiff with a continuing personal stake sufficient to satisfy Article III.64 The majority's approach dilutes the case-or-controversy requirement into a prudential guideline.65
The case should have been dismissed or remanded for consideration of mootness and adequacy of representation.66