Thompson was a pregnant, nineteen-year-old mother of one child who applied for assistance under the Aid to Families with Dependent Children (AFDC) program in Connecticut after having recently moved there from Massachusetts. Connecticut denied her aid since she did not satisfy the state's one-year residency requirement. This case was decided together with Washington v. Legrant and Reynolds v. Smith. In Washington, three people applied for and were denied AFDC aid on the ground that they had not resided in the District of Columbia for one year immediately preceding the filing of their application In Reynolds, two appellees, Smith and Foster, were denied AFDC aid on the sole ground that they had not been residents of Pennsylvania for at least a year prior to their applications as required by a Pennsylvania Welfare Code.
Does the conditioning of AFDC aid on various residency requirements violate the Fourteenth Amendment's Equal Protection Clause?
Yes. The Court held that since the regulation touched "on the fundamental right of interstate movement," it must promote a compelling state interest. Connecticut, Pennsylvania, and Washington DC, all failed to advance any compelling administrative or social reasons for their requirements. The goal of simply preventing indigents from moving to these states was constitutionally impermissible, argued Justice Brennan, given the value the United States has historically placed on the freedom to travel.
Decisions
Decision: 6 votes for Thompson, 3 vote(s) against Legal provision: Equal Protection
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Full Opinion by Justice William J. Brennan, Jr.
