Wednesday, November 13, 2013

Matthews v. Diaz case brief

Matthews v. Diaz case brief summary
426 U.S. 67 (1976)

Defendant Secretary of Health, Education, and Welfare appealed from a judgment of the United States District Court for the Southern District of Florida, which found in favor of plaintiff resident aliens, holding that a requirement that an alien reside in the United States for a five-year continuous period in order to participate in a federal medical insurance program was unconstitutional.


  • Plaintiffs had been lawfully admitted to the United States for less than five years. 
  • Plaintiffs were over 65 years old and had been denied enrollment in the Medicare Part B supplemental medical insurance program under 42 U.S.C.S. § 1395j et seq. 
  • They attacked the statutory basis for the denial under 42 U.S.C.S. § 1395o(2), which granted eligibility to resident citizens who were 65 or older but which denied eligibility to comparable aliens unless they had been admitted for permanent residence and also resided in the United States on a continuous basis for at least five years. 
  • The District Court held that the five-year residence requirement violated the Due Process Clause of the Fifth Amendment and that the alien-eligibility provisions of 42 U.S.C.S. § 1395o(2)(B) were unenforceable.

On appeal, the court reversed, finding that 42 U.S.C.S. § 1395o(2)(B) had not deprived appellees of liberty or property without due process of law. Aliens were not entitled to enjoy all the advantages of citizenship, and a legitimate distinction between citizens and aliens justified benefits for one class that were not accorded to the other.


The court reversed the judgment of the district court and held that the five-year continuous residency requirement and the permanent residency requirement were constitutional.

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