Sosna v. Iowa case brief

Sosna v. Iowa case brief summary
419 U.S. 393 (1975)

CASE SYNOPSIS

In a class action, appellant ex-husband sought to litigate the constitutionality of the durational residency requirement in a representative capacity. Appellant sought review from a judgment of the United States District Court for the Northern District of Iowa, which held that Iowa's one-year residency requirement for invoking its divorce jurisdiction did not violate the Due Process Clause of the Fourteenth Amendment.

CASE FACTS
Appellant filed a complaint in federal district court, asserting that Iowa's one-year residency requirement for invoking its divorce jurisdiction violated the United States Constitution. A three-judge court held that the requirement was constitutional, and appellant sought review.

DISCUSSION

• The court affirmed. 
• The court held that the class action was not rendered moot by the fact that the individual appellant's claim had become moot. 
• The requirement was unlike those struck down in other counties because they infringed the constitutional right to travel. 
• According to the court, the requirements at issue in the earlier county cases were justified solely on the basis of budgetary or recordkeeping considerations, but Iowa's requirement was based on the State's interest in requiring that those who sought a divorce from its courts were genuinely attached to the State, as well as a desire to insulate divorce decrees from the likelihood of collateral attack. 
• The statute's failure to provide an individualized determination of residency did not violate due process, because a litigant's rights were merely being delayed, not denied.

CONCLUSION
The Court affirmed the judgment of the district court.


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