Sunday, December 8, 2013

Shapiro v. Thompson case brief

Shapiro v. Thompson case brief summary
394 U.S. 618 (1969)


CASE SYNOPSIS
Petitioners appealed judgments from the United States District Court for the District of Connecticut, which struck down statutes denying public benefits to residents of a state or District of Columbia who had not resided in the jurisdictions for at least a year preceding their applications for assistance. The ruling was premised on a finding that the statutes restricted the exercise of a fundamental right based on an impermissible classification.

CASE FACTS
Petitioners sought review of judgments, which held unconstitutional, under U.S. Constitutional Amendment XIV (Equal Protection Clause), statutory provisions denying welfare assistance to residents of a state or District of Columbia who had not resided within the jurisdictions for at least a year immediately preceding their applications for assistance.

DISCUSSION
  • The Court held respondents had a constitutional right to travel from one state to another, and the challenged laws, which penalized the exercise of that right based on a classification created by the one-year waiting period, unless shown to be necessary to promote a compelling governmental interest, were unconstitutional. 
  • The Court held that while a state had an interest in preventing fraud in applications, and in reducing costs of welfare programs, the classification imposed was impermissible where less drastic measures were available to protect a state's interest. 
  • The Court also held that even if federal statutes appeared to authorize a state to adopt such a classification, Congress was not empowered to direct a state to violate the Equal Protection Clause. 
  • Accordingly, judgments holding challenged statutes unconstitutional were affirmed.

CONCLUSION
Judgments holding statutory provisions unconstitutional were affirmed where respondents had a constitutional right to travel from one state to another and the challenged laws, which penalized the exercise of that right based on an impermissible classification, were unconstitutional where they were not necessary to promote a compelling governmental interest.


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