Memorial Hosp. v. Maricopa County
Annotate this Case
415 U.S. 250 (1974)
U.S. Supreme Court
Memorial Hosp. v. Maricopa County, 415 U.S. 250 (1974)
Memorial Hospital v. Maricopa County
Argued November 6, 1973
Decided February 26, 1974
415 U.S. 250
This is an appeal from a decision of the Arizona Supreme Court upholding the constitutionality of an Arizona statute requiring a year's residence in a county as a condition to an indigent's receiving nonemergency hospitalization or medical care at the county's expense.
Held: The durational residence requirement, in violation of the Equal Protection Clause, creates an "invidious classification" that impinges on the right of interstate travel by denying newcomers "basic necessities of life." Shapiro v. Thompson, 394 U. S. 618. Pp. 415 U. S. 253-270.
(a) Such a requirement, since it operates to penalize indigents for exercising their constitutional right of interstate migration, must be justified by a compelling state interest. Shapiro v. Thompson, supra; Dunn v. Blumstein, 405 U. S. 330. Pp. 415 U. S. 253-262.
(b) The State has not shown that the durational residence requirement is "legitimately defensible" in that it furthers a compelling state interest, and none of the purposes asserted as justification for the requirement -- fiscal savings, inhibiting migration of indigents generally, deterring indigents from taking up residence in the county solely to utilize the medical facilities, protection of longtime residents who have contributed to the community particularly by paying taxes, maintaining public support of the county hospital, administrative convenience in determining bona fide residence, prevention of fraud, and budget predictability -- satisfies the State's burden of justification and insures that the State, in pursuing its asserted objectives, has chosen means that do not unnecessarily impinge on constitutionally protected interests. Pp. 415 U. S. 262-269.
108 Ariz. 373, 498 P.2d 461, reversed and remanded.
MARSHALL, J., delivered the opinion of the Court, in which BRENNAN, STEWART, WHITE, and POWELL, JJ., joined. BURGER, C.J., and BLACKMUN, J., concurred in the result. DOUGLAS, J., filed a separate