GRAHAM v. RICHARDSON

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Case Basics
Docket No. 
609
Appellant 
John O. Graham, Commissioner, Department of Public Welfare, State of Arizona
Appellee 
Carmen Richardson et al.
Consolidation 
No. 727, Sailer et al. v. Leer et al.
Advocates
(argued the cause for the appellant in No. 609)
(argued the cause for the appellants in No. 727)
(argued the cause for the appellees in No. 609)
(argued the cause for the appellees in No. 727, pro hac vice)
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Facts of the Case 

The state of Arizona restricts the distribution of welfare benefits to individuals who are either United States citizens or aliens who have lived in the country for at least 15 years. In 1969, Carmen Richardson, a resident alien of Arizona who met all requirements for welfare eligibility except the residency requirement, filed a class action lawsuit against the Commissioner of the State's Department of Public Welfare questioning the constitutionality of that requirement. The three-judge court in the District of Arizona found in favor of Richardson, but the Commissioner appealed. In the same year, a similar class action suit was filed in the Eastern District of Pennsylvania. In this case, resident aliens of Pennsylvania challenged state law which dictated that if a Pennsylvania resident did not qualify for federal aid then he or she could only receive welfare benefits from the state if he or she were a citizen or had applied for citizenship. This three-judge court also found in favor of the resident aliens. However, one judge disagreed, and the defendants, namely the Executive Director of the Philadelphia County Board of Assistance and the Secretary of the Commonwealth's Department of Public Welfare, appealed.

Question 

Does a state, like Arizona or Pennsylvania, violate the Equal Protection Clause of the Fourteenth Amendment when it denies welfare benefits to those who are not United States citizens or to aliens who have not lived in this country for a certain number of years?

Conclusion 
Decision: 9 votes for Richardson, 0 vote(s) against
Legal provision: Equal Protection

Yes. In a unanimous opinion authored by Justice Harry A. Blackmun, the Court asserted that to classify state residents solely based on alienage was inherently questionable, because aliens constitute a minority, separate from the rest of the population. The Court conceded that there had been instances in which state laws could treat citizens and non-citizens differently. However, it maintained that a state’s aim to conserve welfare benefits for citizens would not legitimize the denial of welfare benefits to aliens. Their justification was that the aliens pay taxes and, consequently, contribute to the pool of money from which welfare benefits are drawn. As a result, the Supreme Court concluded that the welfare benefit restrictions violate the Equal Protection Clause of the Fourteenth Amendment.

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GRAHAM v. RICHARDSON. The Oyez Project at IIT Chicago-Kent College of Law. 15 April 2014. <http://www.oyez.org/cases/1970-1979/1970/1970_609>.
GRAHAM v. RICHARDSON, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1970-1979/1970/1970_609 (last visited April 15, 2014).
"GRAHAM v. RICHARDSON," The Oyez Project at IIT Chicago-Kent College of Law, accessed April 15, 2014, http://www.oyez.org/cases/1970-1979/1970/1970_609.