Rivera v. Dunn

329 F. Supp. 554, 1971 U.S. Dist. LEXIS 12226
CourtDistrict Court, D. Connecticut
DecidedJuly 29, 1971
DocketCiv. 14517
StatusPublished
Cited by10 cases

This text of 329 F. Supp. 554 (Rivera v. Dunn) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rivera v. Dunn, 329 F. Supp. 554, 1971 U.S. Dist. LEXIS 12226 (D. Conn. 1971).

Opinion

MEMORANDUM OF DECISION

J. JOSEPH SMITH, Circuit Judge:

This action was brought in the United States District Court for the District of Connecticut seeking a declaratory judgment pursuant to 28 U.S.C. §§ 2201, 2202 striking down as unconstitutional a statute recently enacted by the legislature of Connecticut requiring persons receiving public assistance to have been residents of the state for at least one *555 year. 1 The plaintiffs also seek a permanent injunction against the statute’s enforcement and the payment of funds unconstitutionally withheld.

On July 16, 1971 a temporary restraining order was entered by the district court enjoining the continued enforcement of the statute. This three-judge court was then convened by the Chief Judge of this circuit pursuant to 28 U.S.C. §§ 2281 and 2284. The plaintiffs have moved that this action proceed as a class action in accordance with Rule 23(a), Federal Rules of Civil Procedure, with the plaintiffs representing a class composed of all persons eligible for the receipt of public assistance except for their failure to meet the one-year residency requirement. The defendants have concurred in this motion, and the court therefore designates this as an appropriate class.

The members of this court are not unfamiliar with the issues raised by this case since two of its present members sat on the three-judge district court which invalidated a Connecticut statute virtually identical with that at issue here. [Thompson v. Shapiro, 270 F.Supp. 331 (D.Conn.1967)] The decision of that court was, of course, affirmed by the Supreme Court in Shapiro v. Thompson, 394 U.S. 618, 89 S.Ct. 1322, 22 L.Ed.2d 600 (1968), and Mr. Justice Brennan’s opinion for the Court in that case is dispositive here.

The Court based its opinion in Shapiro squarely on the previously established right of citizens of the United States to travel between the several states “uninhibited by statutes, rules, or regulations which unreasonably burden or restrict this movement.” 2 The Court reviewed the long line of cases which established this right beginning with the Passenger Cases, [Smith v. Turner, Norris v. Boston] 7 How. 283, 492, 12 L.Ed. 702 (1849), and quoted with approval Mr. Justice Stewart’s statement for the Court in United States v. Guest, 383 U. S. 745, 757-758, 86 S.Ct. 1170, 1178, 16 L.Ed.2d 239 (1966):

The constitutional right to travel from one State to another * * * occupies a position fundamental to the concept of our Federal Union. It is a right that has been firmly established and repeatedly recognized. * * * [T]hat right finds no explicit mention in the Constitution. The reason, it has been suggested, is that a right so elementary was conceived from the beginning to be a necessary concomitant of the stronger Union the Constitution created. In any event, freedom to travel throughout the United States has long been recognized as a basic right under the Constitution.

Since the Court found that the residency requirement acted to impede a “fundamental” right, its constitutionality would not be measured by the “rational connection” test usually employed for equal protection purposes. As the Court# pointed out, the waiting period requirement based on classification by length of residence, touching as it does on a fundamental right of interstate movement, *556 clearly violates the Equal Protection Clause of the first section of the Fourteenth Amendment,. 3

The waiting-period provision denies welfare benefits to otherwise eligible applicants solely because they have recently moved into the jurisdiction. But in moving from State to State or to the District of Columbia appellees were exercising a constitutional right, and any classification which serves to penalize that right, unless shown to promote a compelling governmental interest, is unconstitutional. [394 U.S. at 634, 89 S.Ct. at 1331 (emphasis in original)].

Whether reduction in benefits to all may result from furnishing aid to all, or whether the state can or should raise additional funds, or cut the level of assistance still further are questions for the governor and legislature. The state cannot, however, ignore the Constitution and the Supreme Court’s decision in Shapiro v. Thompson, and alleviate its problems by an arbitrary discrimination against some of its people resident in the state by classification on the basis of length of residence. Since the Court decided Shapiro, the lower courts have uniformly struck down all manner of attempts to establish durational residency requirements for state and local welfare. 4 Only recently the Supreme Court in Graham v. Richardson, 403 U.S. 365, 91 S.Ct. 1848, 29 L.Ed.2d 534 (1971), (June 14, 1971) (Blackmun, J.) reaffirmed its continued adherence to the principles set forth in Shapiro in invalidating statutes which conditioned an alien’s welfare eligibility upon his length of residence in this country.

Since an alien as well as a citizen is a “person” for equal protection purposes, a concern for fiscal integrity is no more compelling a justification for the questioned classification in these cases than it was in Shapiro.

The State of Connecticut attempts to argue, however, that there now exists a sufficiently compelling state interest to justify the minimum residency requirement in spite of its effect on constitutionally protected rights. The statute includes a long preamble which is here set forth in the margin in which the legislature explained why it felt such a compelling interest to exist. 5

*558 It appears from the testimony that applications for public assistance are made initially to local welfare departments, which may grant general assistance pending action on applications for state assistance in the categories eligible for such assistance. The state reimburses the local government for 90% of aid furnished.

• Testimony based on a pre-audit of the records of welfare departments of the 8 towns of the 169 towns of the state which account for 82% of the welfare cases in the state was to the effect that approximately 17.6% of recent applicants had resided in the state less than one year. The pre-audit report itself was not produced, its makers were not subject to examination, and its weight is questionable. No showing was made that the percentage of recipients

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415 U.S. 250 (Supreme Court, 1974)
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339 F. Supp. 738 (D. New Jersey, 1972)
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Opinion of the Justices to the House of Representatives
273 N.E.2d 879 (Massachusetts Supreme Judicial Court, 1971)

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Bluebook (online)
329 F. Supp. 554, 1971 U.S. Dist. LEXIS 12226, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rivera-v-dunn-ctd-1971.