In moving from state to state or to the District of Columbia a person exercises a constitutional right, and any classification which serves to penalize the exercise of that right, unless shown to be necessary to promote a compelling governmental interest, is unconstitutional.
A district court struck down statutes for being unconstitutional and against equal protection for denying public benefits to residents of a state or the District of Columbia who had not resided in the jurisdictions for at least a year preceding their applications for assistance. The ruling was premised on a finding that the statutes restricted the exercise of a fundamental right based on an impermissible classification. The Court held that a constitutional right to travel from one state to another outweighted the challenged laws, which penalized the exercise of that right based on a classification created by the one-year waiting period, unless shown to be necessary to promote a compelling governmental interest.
Were the statutes unconstitutional?
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.