Saenz v. Roe,
526 U.S. 489 (1999)
California, which has the sixth highest welfare benefit levels in the country, sought to amend its Aid to Families with Dependent Children (AFDC) program in 1992 by limiting new residents, for the first year they live in the State, to the benefits they would have received in the State of their prior residence. Cal. Welf. & Inst. Code Ann. §11450.03. Although the Secretary of Health and Human Services approved the change--a requirement for it to go into effect--the Federal District Court enjoined its implementation, finding that, under Shapiro v. Thompson, 394 U. S. 618 , and Zobel v. Williams, 457 U. S. 55 , it penalized "the decision of new residents to migrate to [California] and be treated [equally] with existing residents," Green v. Anderson , 811 F. Supp. 516, 521. After the Ninth Circuit invalidated the Secretary's approval of §11450.03 in a separate proceeding, this Court ordered Green to be dismissed. The provision thus remained inoperative until after Congress enacted the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), which replaced AFDC with Temporary Assistance to Needy Families (TANF). PRWORA expressly authorizes any State receiving a TANF grant to pay the benefit amount of another State's TANF program to residents who have lived in the State for less than 12 months. Since the Secretary no longer needed to approve §11450.03, California announced that enforcement would begin on April 1, 1997. On that date, respondents filed this class action, challenging the constitutionality of §11450.03's durational residency requirement and PRWORA's approval of that requirement. In issuing a preliminary injunction, the District Court found that PRWORA's existence did not affect its analysis in Green. Without reaching the merits, the Ninth Circuit affirmed the injunction.
Held: Section 11450.03 violates Section 1 of the Fourteenth Amendment.
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