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Saenz v. Roe

526 U.S. 489 (1999)

tl;dr: Court strikes a law down as unconstitutional on the basis of privileges/immunities clause.

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The case of Saenz v. Roe involved a California statute that limited welfare benefits for newly arrived residents. The plaintiffs challenged the constitutionality of the statute, alleging that it violated their constitutional rights. The lower court upheld the statute, but the Supreme Court found it unconstitutional, as it violated the right to travel and the privileges and immunities clause of the Constitution. The Court also found that the 1996 amendment to the Social Security Act did not affect the determination of the statute's constitutionality. The District Court and Court of Appeals found the statute unconstitutional as it penalized new residents and created significant differences in benefit levels without considering varying costs of living. The Supreme Court was unable to reach a decision on the case due to invalidation of the Secretary's approval, and the statute remained inoperative until the enactment of a new law. The All County Letter clarified that benefits for eligible family members will be determined by the law of their state of residence during a certain time period if it was lower than California's, but the residency requirement does not apply to families who recently arrived from another country. In 1997, a lawsuit was filed in California challenging the constitutionality of PRWORA's approval of the durational residency requirement. The judge concluded that PRWORA allowed, but did not require, states to impose durational residency requirements, and that the existence of the federal statute did not affect his prior opinion in Green. The judge issued an injunction against the implementation of the statute, as it violated the constitutional rights of new residents.

The Constitution guarantees the right to travel and prohibits durational residency requirements that inhibit it. Discrimination against newly arrived citizens is unconstitutional, and the right to be treated equally is protected by the Privileges or Immunities Clause. Congressional approval of durational residency requirements does not make discriminatory state laws constitutional. The constitutionality of a specific section is being questioned, and further inquiry is needed to determine its validity. States can establish reasonable criteria for in-state status to prevent non-residents from taking advantage of in-state rates. Durational residency requirements for welfare benefits are necessary to prevent a significant impact on a state's budget. Justice Thomas dissents from the majority's conclusion.

Justice Washington's interpretation of the Privileges and Immunities Clause in Corfield limited its protection to fundamental rights. The Fourteenth Amendment guarantees fundamental rights. The majority's conclusion that a State violates the Clause by discriminating against citizens who have been domiciled in the State for less than a year in the distribution of welfare benefits is questionable. The dissent suggests that the Clause's historical underpinnings and place in constitutional jurisprudence should be reevaluated before invoking it and raises concerns that it may become a tool for inventing new rights based on the preferences of the current Court members.

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Facts & Holding

Facts:In 1992, CA enacted a statue that limited the maximum...

Holding:Constitutional right to travel from one state to another is...

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Saenz v. Roe

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