Mem'l Hosp. v. Maricopa Cty. - 415 U.S. 250, 94 S. Ct. 1076 (1974)

Rule:

A state may not protect the public fisc by drawing an invidious distinction between classes of its citizens. The conservation of the taxpayers' purse is simply not a sufficient state interest to sustain a durational residence requirement, which, in effect, severely penalizes exercise of the right to freely migrate and settle in another state. 

Facts:

An indigent who had resided in Maricopa County, Arizona for approximately 1 month was admitted to a nonprofit, private community hospital for treatment of a respiratory illness. Thereafter, pursuant to an Arizona statute governing medical care for indigents, the private hospital requested that the indigent be transferred to the county's public hospital facility and that the county reimburse the private hospital for care and services provided to the indigent. Relying on an Arizona statute requiring an indigent to be a resident of a county for the preceding 12 months in order to be eligible for free nonemergency medical care, the county refused both requests because the indigent did not meet the residency requirement. An action was then instituted to determine whether the county was obligated to provide medical care for the indigent or was liable to the private hospital for the costs it sustained in treating the indigent. Although the trial court held that the residency requirement was violative of the equal protection clause of the Fourteenth Amendment, the Arizona Supreme Court reversed and upheld the constitutionality of the challenged requirement.

Issue:

Was the Arizona statute requiring a year's residence in a county as a condition to an indigent's receiving nonemergency hospitalization or medical care at the county's expense constitutional?

Answer:

No.

Conclusion:

The Supreme Court of the United States reversed the judgment. The requirement impinged on the indigent's constitutional right of interstate travel because it penalized intrastate travel, and the denial of non-emergency medical care had the possibility of deterring migration. The requirement could not be upheld because it did not further a compelling state interest. The county’s claimed fiscal savings were an insufficient state interest to uphold the requirement. Further, the Equal Protection Clause prohibited the county from apportioning benefits and services based upon the past tax contributions of its citizens. Less intrusive alternatives were available to protect the county from fraud and to assist defendant with budge predictability.