Saenz v. Roe

526 U.S. 489 (1999)


California enacted a welfare statute that limited the maximum welfare benefits available to newly arrived residents. The statute limited the amount payable to a family that has resided in California for less than 12 months to the amount payable by the State of the family's prior residence. Ps were former residents of Louisiana and Oklahoma where they would get $191 and $341 for a family of three even though the full California grant was $641. The District Court used the Shapiro analysis to determine that this statute placed a penalty on the decision to migrate. The court also concluded that the existence of the Work Opportunity Reconciliation Act of 1996, which allowed such statutes as California's, did not affect the legal analysis of Shapiro. The Court of Appeals affirmed the lower court's preliminary injunction. The Supreme Court granted certiorari.