Saenz V. Roe - Background

Background

In 1992, the state of California enacted a statute limiting the maximum welfare benefits available to newly arrived residents. At the time, California was paying the sixth-largest welfare benefits in the United States. In a move to reduce the state welfare budget, the California State Legislature enacted a statute (Cal. Welf. & Inst. Code Ann. §11450.03) to limit 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. For the state to comply with the then-existent Aid to Families with Dependent Children program, it needed a waiver from the United States Secretary of Health and Human Services (HHS) in order to qualify for federal reimbursement. Louis Wade Sullivan, who was HHS Secretary at that point, granted his approval in October 1992.

On December 21, 1992, three California residents who were eligible for AFDC benefits filed an action in the United States District Court for the Eastern District of California, challenging the constitutionality of the durational residency requirement. All of the plaintiffs had alleged that they had moved into California to escape abusive family situations. The District Court judge temporarily enjoined the state from enforcing the statute, and the state petitioned the court for certiorari. In a separate proceeding, the HHS Secretary's approval of the statute was invalidated and so so the Court did not reach the merits of the case.

In 1996, President Bill Clinton signed the Personal Responsibility and Work Opportunity Act (PRWORA) into law, which created the Temporary Assistance for Needy Families (TANF) program and expressly permitted states to limit aid to people who had been residents for less than a year. No longer requiring the approval of federal authorities, California began enforcing the statute.