Saenz v. Roe
Supreme Court of the United States Image File history File links Seal_of_the_United_States_Supreme_Court. ...
Argued January 13, 1999 Decided May 17, 1999
Full case name: Rita L. Saenz, Director, California Department of Social Services, et al., Petitioners v. Brenda Roe & Anna Doe etc. Citations: 526 U.S. 489; 119 S. Ct. 1518; 143 L. Ed. 2d 689; 1999 U.S. LEXIS 3174; 67 U.S.L.W. 4291; 99 Cal. Daily Op. Service 3574; 99 Daily Journal DAR 4559; 1999 Colo. J. C.A.R. 2812; 12 Fla. L. Weekly Fed. S 227; 61 Soc. Sec. Rep. Service 75 Prior history: On certiorari from the United States Court of Appeals for the Ninth Circuit Subsequent history: ---
Holding
§11450.03 unconstitutionally discriminated against new residents of California, in contravention of their right to travel.
Court membership
Chief Justice: William Rehnquist Associate Justices: John Paul Stevens, Antonin Scalia, Sandra Day O'Connor, Stephen Breyer, Clarence Thomas, Anthony M. Kennedy, David Souter, Ruth Bader Ginsburg
Case opinions
Majority by: Stevens Joined by: Ginsburg, Breyer, O'Connor, Scalia, Kennedy, Souter Dissent by: Rehnquist Joined by: Thomas Dissent by: Thomas Joined by: Rehnquist
Laws applied
U.S. Const. Art. 4 § 2, Amend. XIV § 1

Saenz v. Roe, 526 U.S. 489 (1999)^[1], was a case in which the Supreme Court of the United States discussed how the constitutional right to travel from one state to another is a part of American jurisprudence. William Hubbs Rehnquist (October 1, 1924 – September 3, 2005) was an American lawyer, jurist and political figure, who served as an Associate Justice on the Supreme Court of the United States and later as the Chief Justice of the United States. ... John Paul Stevens (born April 20, 1920) is an American jurist and the senior Associate Justice of the U.S. Supreme Court. ... Antonin Gregory Scalia (born March 11, 1936) is an American jurist who has been a prominent conservative and originalist voice on the Supreme Court of the United States of America, and one of the most outspoken advocates of textualism in statutory interpretation and original meaning in constitutional interpretation. ... Sandra Day OConnor (born March 26, 1930) is a former American jurist and politician who served as the first female Associate Justice of the Supreme Court of the United States from 1981 to 2006. ... Stephen Gerald Breyer (born August 15, 1938) is an American attorney, political figure, and jurist. ... Clarence Thomas (born June 23, 1948) is an American jurist and has been an Associate Justice of the Supreme Court of the United States since 1991. ... Justice Anthony Kennedy Anthony McLeod Kennedy (born July 23, 1936) has been a US Supreme Court Associate Justice since 1988. ... David Hackett Souter (born September 17, 1939) has been an Associate Justice of the U.S. Supreme Court since 1990. ... Ruth Joan Bader Ginsburg (born March 15, 1933) is a United States jurist. ... // Case citation is the system used in common law countries such as the United States, England and Wales, Canada, New Zealand, Australia and India to uniquely identify the location of past court cases in special series of books called reporters. ... 1999 (MCMXCIX) was a common year starting on Friday, and was designated the International Year of Older Persons by the United Nations. ... The Supreme Court of the United States is the highest judicial body in the U.S. and leads the judicial branch of the U.S. federal government. ... The Berlin Wall restricted freedom of movement between East and West Germany after WWII Freedom of movement, mobility rights or the right to travel is a human rights concept which is respected in the constitutions of numerous Western states. ... Jurisprudence is essentially the theory and philosophy of law. ...

Background

In 1992, the state of California enacted a statute limiting the maximum welfare benefits available to newly-arrived residents. At the time, California was paying the sixth-largest welfare benefits in the United States. In a move to reduce the state welfare budget, the California State Legislature enacted a statute (Cal. Welf. & Inst. Code Ann. §11450.03) to limit new residents, for the first year they live in the State, to the benefits they would have received in the State of their prior residence. In order for the state to comply with the then-existant Aid to Families with Dependent Children program, it needed receive a waiver from the United States Secretary of Health and Human Services (HHS) in order to qualify for federal reimbursement. Louis Wade Sullivan, who was HHS Secretary at that point, granted his approval in October 1992. 1992 (MCMXCII) was a leap year starting on Wednesday. ... Official language(s) English Capital Sacramento Largest city Los Angeles Area  Ranked 3rd  - Total 158,302 sq. ... A statute is a formal, written law of a country or state, written and enacted by its legislative authority, perhaps to then be ratified by the highest executive in the government, and finally published. ... Welfare is financial assistance paid by the government to certain entities or groups of people who are unable to support themselves alone, or are perceived by the government to be able to function more effectively with financial assistance. ... Californias Capitol, where the State Legislature meets California State Assembly chamber California state Senate chamber The California Legislature is the legislative branch of the state government of California. ... Aid to Families with Dependent Children(AFDC) is the name of a welfare program in effect between August 14, 1935 and June 30, 1997, administered by the United States Department of Health and Human Services. ... The United States Secretary of Health and Human Services is the head of the United States Department of Health and Human Services, concerned with The Secretary is a member of the Presidents Cabinet. ... Louis Wade Sullivan (born November 3, 1933) is an American physician. ... Look up October in Wiktionary, the free dictionary. ...

On December 21, 1992, three California residents who were eligible for AFDC benefits filed an action in the United States District Court for the Eastern District of California, challenging the constitutionality of the durational residency requirement. Each of the plaintiffs had alleged that they had moved into California to escape abusive family situations. The District Court judge temporarily enjoined the state from enforcing the statute, and the state petitioned the court for certiorari. But in a separate proceeding, the HHS Secretary's approval of the statute was invalidated, so the Court did not reach the merits of the case. The U.S. District Court for the Eastern District of California is composed of six divisions. ... The plaintiff, claimant, or complainant is the party initiating a lawsuit, (also known as an action). ... Domestic violence occurs when a family member, partner or ex-partner attempts to physically or psychologically dominate or harm the other. ... An injunction is an equitable remedy in the form of a court order that either prohibits or compels (restrains or enjoins) a party from continuing a particular activity. ... This law-related article does not cite its references or sources. ...

In 1996, President Bill Clinton signed the Personal Responsibility and Work Opportunity Act (PRWORA) into law. The Act created the Temporary Assistance for Needy Families (TANF) program, and expressly permitted states to limit aid to people who people who had been residents for less than a year. No longer requiring the approval of federal authorities, California began enforcing the statute. 1996 (MCMXCVI) was a leap year starting on Monday of the Gregorian calendar, and was designated the International Year for the Eradication of Poverty. ... The Personal Responsibility and Work Opportunity Act of 1996, passed under the Clinton administration, was a fundamental shift in both the method and goal of cash assistance to the poor. ...

Facts & Procedural History

In 1997 the two plaintiffs in this case sued in the same court as the prior litigants, this time challenging both the California statute and the PRWORA's durational residency provision. The district court certified the case as a class action and issued a preliminary injunction. While the State argued that the statute was a legitimate use of its police powers (because it was laregly a budgetary measure), the district court still found for the plaintiffs and enjoined enforcement of the statute, on the grounds that it discriminated between newcomers to the state and long-time residents. The United States Court of Appeals for the Ninth Circuit affirmed. The United States district courts are the general trial courts of the United States federal court system. ... In law, a class action is an equitable procedural device used in litigation for determining the rights of and remedies, if any, for large numbers of people whose cases involve common questions of law and fact. ... An injunction is an equitable remedy in the form of a court order that either prohibits or compels (restrains or enjoins) a party from continuing a particular activity. ... Police Power is the constitutional authority of the state to pass and enforce laws to protect and promote the public safety, health, general welfare, and morals of a community. ... The U.S. Court of Appeals for the Ninth Circuit is a federal court with appellate jurisdiction over the district courts in the following districts: District of Alaska District of Arizona Central, Eastern, Northern, and Southern Districts of California District of Hawaii District of Idaho District of Montana District of...

Majority opinion

Justice Stevens, writing for the majority, found that although the "right to travel" was not explicitly mentioned in the Constitution, the concept was "firmly embedded in our jurisprudence". He described three components of right to travel: John Paul Stevens (born April 20, 1920) is an American jurist and the senior Associate Justice of the U.S. Supreme Court. ...

1. The right to enter one state & leave another
2. The right to be treated as a welcome visitor rather than a hostile stranger (this is covered by Article IV, §2)
3. For those who become permanent residents, the right to be treated equally to native born citizens (this is covered by the 14th Amendment Privileges or Immunities clause).

Because the statute did not directly impair entry or exit from the state, Stevens declined to discuss the first aspect of the right to travel, although he did mention that the right was expressly mentioned in the Articles of Confederation. He briefly described the scope of the Art. IV Privileges and Immunities clause, but the main focus of his opinion was the application was the application of the "Privileges or Immunities" clause of the Fourteenth Amendment. For the proposition that this clause protected a citizen's right to resettle in other states, Stevens cited the the majority opinion in the Slaughterhouse Cases. Article Four of the United States Constitution relates to the states. ... The Fourteenth Amendment to the United States Constitution is one of the post-Civil War amendments and includes the Due Process and Equal Protection Clauses. ... The Privileges or Immunities Clause is a provision of the Fourteenth Amendment to the United States Constitution. ... The Articles of Confederation The Articles of Confederation and Perpetual Union, commonly known as the Articles of Confederation, was the first governing document of the United States of America. ... Holding The 14th Amendment does not protect the privileges and immunities of state citizenship, only national citizenship. ...

Stevens further held that the fact that the statute only minimally impaired the plaintiffs' right to travel was irrelevant. The plaintiffs were new to the state of California, but they had the right to be treated the same as long-time residents, especially given that their need for welfare benefits was unrelated to the amount of time they had spent in the state. Furthermore, wrote Stevens, there was no reason for the State to fear that citizens of other states would take advantage of California's relatively generous welfare benefits, because the proceeds of each welfare check would be consumed while the plaintiffs remained within the state.

California justified the statute solely on fiscal grounds, and Stevens held that this jusitification was insufficient. The state could have found another non-discriminatory way to reduce welfare costs, other than conditioning the welfare benefit amounts of new residents by reference to their length of stay within the state, or their state of prior residence. Moreover, the fact that PRWORA authorized states to set their own benefit levels did not assist in the determining the constitutionality of the state statute, because Congress cannot authorize states to violate the Fourteenth Amendment. Congress in Joint Session. ...

Rehnquist's dissent

Justice Rehnquist dissented on the grounds that he did not feel that the Fourteenth Amendment's Privileges or Immunities Clause required the result reached by the majority, especially considering that the clause had only been applied a few times since the ratification of the amendment. Rehnquist reasoned that although they are related, the right to become a citizen of another state was not the same as the right to travel. Furthermore, he claimed that that becoming a citizen of another state required both physical presence within the state and a subjective intent to remain there. Since residency requirements pertain to the latter factor of citizenship, Rehnquist reasoned they should not be unconstitutional. William Hubbs Rehnquist (October 1, 1924 – September 3, 2005) was an American lawyer, jurist and political figure, who served as an Associate Justice on the Supreme Court of the United States and later as the Chief Justice of the United States. ...

Thomas' dissent

Justice Thomas dissented separately, because he felt that the majority attributed a meaning to the Fourteenth Amendment Privileges or Immunities Clause that its framers did not intend. He lamented the decision of the Slaughterhouse Cases which basically turned the clause into a nullity. He looked to the historical meaning and use of the language in the clause, citing the 1606 Charter of Virginia, which guaranteed the citizens therein all the "Liberties, Franchises, and Immunities" of a person born in England. He also noted that the phrase was used in the Articles of Confederation, which was then imported into Article IV of the Constitution. Clarence Thomas (born June 23, 1948) is an American jurist and has been an Associate Justice of the Supreme Court of the United States since 1991. ... Events January 27 - The trial of Guy Fawkes and other conspirators begins ending in their execution on January 31 May 17 - Supporters of Vasili Shusky invade the Kremlin and kill Premier Dmitri December 26 - Shakespeares King Lear performed in court Storm buries a village of St Ismails near... Official language(s) English Capital Richmond Largest city Virginia Beach Area  Ranked 35th  - Total 42,793 sq. ... Royal motto (French): Dieu et mon droit (Translated: God and my right) Englands location (dark green) within the United Kingdom (light green), with the Republic of Ireland (blue) to its west Languages None official English de facto Capital None official London de facto Largest city London Area – Total Ranked...

Finally, he suggested that the meaning of the Privileges or Immunities Clause of the Fourteenth Amendment be read the same way that Article IV's Privileges and Immunities Clause was interpreted. He cited Justice Bushrod Washington's interpretation of the latter clause in the famous case of Corfield v. Coryell and stated that this is what the framers of the Fourteenth Amendment had intended. Thomas made a strong case for the revival of the clause, in order to protect fundamental rights of citizens. External link Biography from the OYEZ Project Categories: People stubs | 1762 births | 1829 deaths | U.S. Supreme Court justices ...

External links

• ↑ 526 U.S. 489 Full text of the opinion courtesy of Findlaw.com.
• Summary of case from OYEZ