Shapiro v. Thompson Case Brief

Why is the case important?

Welfare applicants were denied assistance because they resided in the District of Columbia for less than one year prior to filing their application for assistance.

Facts of the case

Thompson was a pregnant, nineteen-year-old mother of one child who applied for assistance under the Aid to Families with Dependent Children (AFDC) program in Connecticut after having recently moved there from Massachusetts. Connecticut denied her aid since she did not satisfy the state’s one-year residency requirement. This case was decided together with Washington v. Legrant and Reynolds v. Smith. In Washington, three people applied for and were denied AFDC aid on the ground that they had not resided in the District of Columbia for one year immediately preceding the filing of their application In Reynolds, two appellees, Smith and Foster, were denied AFDC aid on the sole ground that they had not been residents of Pennsylvania for at least a year prior to their applications as required by a Pennsylvania Welfare Code.

Question

Whether the imposition of a one-year residency requirement on welfare assistant applicants is unconstitutional.

Answer

Justice William Brennan (J. Brennan). Yes. The one-year residency requirement is unconstitutional because it discriminates against need . . . families who have not met the residency requirement even though the status of these families is no different than families meeting the residency requirement. The one-year residency requirement is not supported by a compelling state interest. The statutory provisions violate the constitutional right to travel because it has the effect of inhibiting migration by needy persons into the State. The residency requirement also violates the Due Process Clause of the Fifth Amendment because the requirement denies public assistance to poor persons otherwise eligible solely on the ground that they have not been residents of the state for one year at the time their applications are filed. The judgment is affirmed.

Conclusion

The Court affirmed the ruling of the lower court and 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. It reaffirmed that 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.

  • Case Brief: 1969
  • Appellant: Bernard Shapiro
  • Appellee: Vivian Marie Thompson
  • Decided by: Warren Court

Citation: 394 US 618 (1969)
Argued: May 1, 1968
ReArgued: Oct 23 – 24, 1968
Decided: Apr 21, 1969