Saenz v. Roe case brief

Saenz v. Roe case brief summary

526 U.S. 489 (1999)

CASE SYNOPSIS

Petitioners challenged a decision of the United States Court of Appeals for the Ninth Circuit affirming the federal district court's issuance of a preliminary injunction enjoining implementation of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996.

CASE FACTS
Respondents filed suit challenging the durational residency requirements of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, contending that the residency requirements imposed an unconstitutional burden on a certain class of citizens based upon their length of residency. The district court issued a temporary restraining order enjoining the statute's implementation after concluding that it placed a penalty on new citizens and failed to treat them on an equal basis with existing residents. After the appellate court affirmed, petitioners sought further review.

DISCUSSION

• In affirming, the Supreme Court noted that the protections afforded to citizens under U.S. Constitutional amendment XIV imposed a limitation on the states' powers and concluded that the statute impermissibly affected the rights of newly arrived citizens as to the same privileges and immunities enjoyed by other citizens of the same state, in violation of U.S. Constitutional amendment XIV. 
• The statute discriminated against citizens new to the state, and since the right to travel embraced a citizen's right to be treated equally in his or her new state of residence, the discriminatory classification was itself a penalty.

CONCLUSION
The appellate court order affirming the district court's issuance of a temporary restraining order enjoining implementation of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 was affirmed, because the statute violated the privilege and immunities clause in improperly discriminating against citizens of a state on the basis of their length of residency.

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Saenz v. Roe (1999) (Ct applies P or I Clause of 14^th Am.  for nearly first time in history to invalidate a state law)

Overview: California (D) paid residents who had lived in the state for less than 12 months lower welfare benefits than it paid other residents. Roe (P), representing a class of newly arrived citizens to CA (D), challenged the law on equal protection grounds.  Issue: Does a § providing lower benefits to families who’s lived in a State < 12 months violate the P or I Clause?

Holding (Stevens): Yes à Under the P or I Clause of the 14th Am, a State must provide the same benefits to new residents as it does to other residents. CA law in effect was a restriction on the fundamental right to travel

·         It has always been understood that the P or I Clause of the 14th Am. protects the right to travel, which includes a citizen’s right to be treated equally after residing in a new state (differs from Slaughter-House Cases in which 13^th and 14^th Am. Apply only to former slaves)

·         Scheme may not be justified on ground that it deters welfare applicants from migrating to CA à evidence indicates that the number of such persons is small and does not justify a burden on those w/o such motive

·         Neither the rational basis test nor an intermediate standard should apply here

Dissent (Rehnquist): Court has relied on P or I Clause only once before, and that decision overruled 5 years later. CA’s law is reasonable and is a good-faith residency requirement. 

Dissent (Thomas): Majority attribute a meaning to the P or I clause that the framers did not intend.

Note: Ct. invalidated CA law under P or I clause, rather than Equal Protection clause