Zobel v. Williams

457 U.S. 55 (1982)

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Nature of the Case

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Facts

Beginning in 1980, an Alaska law conferred a tax subsidy to its elderly residents. The subsidy derived from the Alaska 'Permanent Fund' which was composed of a series of large oil windfalls beginning in 1967. The subsidy provided a cash unit per number of years an adult lived in Alaska subsequent to 1959 (date of Alaska statehood). The Appellants alleged that this limitation is invalid under the Equal Protection Clause because it is analogous to the duration residency requirement that the Court has already found to be unconstitutional. The Appellants claimed that the subsidy discriminated against their constitutional right to migrant because new in-state residents received lower compensation than someone living in-state for long period of time. The state presented three reasons to support its law; the subsidy: 1) creates financial incentives for individuals to establish and maintain Alaska residence; 2) encourages prudent management of the Permanent Fund; and, 3) rewards residents who contributed to the community during their long-term residency. The Court evaluated the state law using a rational basis standard of review surmising, that if the law did not pass rational basis scrutiny, there would be no need to engage a strict scrutiny standard of review. The Alaska State Supreme Court upheld the law. The U.S. Supreme Court reversed.