Sosna v. Iowa Case Brief

Why is the case important?

Appellant moved from New York to Iowa and one month later brought suit for divorce in Iowa. Appellant’s husband challenged the jurisdiction of the Iowa court.

Facts of the case

Question

Is the Statute unconstitutional because it establishes two classes of persons and discriminates against those who have recently exercised their right to travel to Iowa?

Answer

The Statute passes constitutional muster under both inquiries.
Previous precedent has invalidated durational residency requirements in areas such as qualification for welfare payments, voting, and medical care. However, none of these cases suggested that the States could never impose durational residency requirements. Appellant was not irretrievable foreclosed from obtaining some part of what she sought. Additionally, Iowa’s requirement may be reasonably justified on grounds other than the purely budgetary or administrative considerations claimed in the previous precedent. Such a requirement recognizes that both spouses are interested in the proceedings, avoids officious intermeddling in matters in which another State has a paramount interest, and minimizes the susceptibility of its own divorce decrees to collateral attack.

Conclusion

The Supreme Court of the United States held that the one-year residency requirement was valid. 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.

  • Case Brief: 1975
  • Appellant: Sosna
  • Appellee: Iowa
  • Decided by: Burger Court

Citation: 419 US 393 (1975)
Argued: Oct 17, 1974
Decided: Jan 14, 1975