Saenz v. Roe, 526 U.S. 489 (U.S. 1999)
Facts
In 1997, the plaintiffs sued challenging both the California statute and PRWORA’s durational residency provision. This statute and provision allowed only California residents to receive certain benefits from the state and required newcomers to have lived in CA a certain amount of time prior to receiving these benefits. The state argued that the statute was a legitimate use of its police powers (because budgetary measures). The plaintiff argued that it was discriminatory against newcomers.
Procedural Posture
The District Court held in favor of the plaintiffs on the ground that the enforced statute discriminated between newcomers to the state and long time residents. State of California appealed to the 9th Circuit Court of Appeals. The United States Court of Appeals for the 9th Circuit affirmed the District Court’s decisions and deemed the law illegal.
Holding
The United States Supreme Court held that the California statute was unconstitutional.
Important Dicta and Discussion
The main discussion in this case was “the right to travel.†Justice Stevens found that although not explicitly mentioned in the Constitution, the concept was “firmly embedded in our jurisprudence.†Further, he described the three components of the “right to travel†which include: (1) The right to enter one state and leave another; (2) the right to be treated as a welcome visitor rather than a hostile stranger; (3) for those who want to become permanent residents, the right to be treated equally to native born citizens.
The first aspect was not addressed because the statute did not directly impair entry or exit from the state. Justive Stevens briefly addressed the Privileges and Immunities Clause, but then went on to discuss the Fourteenth Amendment. They cited the Slaughterhouse Cases as authority to describe that this amendment protected a citizen’s right to resettle in other states.
The Court held that the law was unconstitutional because need for welfare benefits is unrelated to the amount of time spent in the state. Fiscal grounds were not enough for the state to prove the need for this statute because there are other non-discriminatory ways of reducing the costs reduced by the statute.
Likely Future Importance
Interstate migration is considered a constitutional inherent right and therefore cannot be taken away from any citizen.