Harlow v. Fitzgerald
72 L. Ed. 2d 672, 102 S. Ct. 2309 (1982)
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Rule of Law:
A state statutory scheme that distributes benefits to citizens based on the length of their residency violates the Equal Protection Clause of the Fourteenth Amendment because rewarding citizens for past contributions is not a legitimate state purpose for creating such classifications.
Facts:
- In 1967, large oil reserves were discovered on state-owned land in Alaska, resulting in a significant financial windfall for the state.
- In 1976, Alaska amended its constitution to establish the Permanent Fund, into which the state was required to deposit at least 25% of its annual mineral income.
- The Fund's principal could not be spent, but its earnings could be used for general governmental purposes.
- In 1980, the Alaska legislature enacted a dividend program to distribute a portion of the Fund's earnings annually to the state's adult residents.
- The program granted each eligible citizen one dividend unit for each year of residency since 1959, the year of Alaska's statehood.
- For the first year, each unit was valued at $50, meaning a one-year resident received $50, while a resident since 1959 received 21 units, or $1,050.
- Appellants Ronald and Patricia Zobel had been residents of Alaska since 1978 and therefore qualified for a smaller dividend than long-time residents.
Procedural Posture:
- Appellants Ronald and Patricia Zobel filed a lawsuit in the Superior Court for Alaska's Third Judicial District against the state's Commissioner of Revenue.
- The Superior Court (trial court) granted summary judgment in favor of the Zobels, holding that the dividend plan violated the Equal Protection Clause and the constitutional right to travel.
- The Commissioner of Revenue appealed this decision to the Alaska Supreme Court.
- A divided Alaska Supreme Court reversed the trial court's judgment and upheld the statute's constitutionality.
- The Zobels appealed the Alaska Supreme Court's decision to the Supreme Court of the United States, which noted probable jurisdiction.
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Issue:
Does a state statute that distributes income from natural resources to adult citizens in varying amounts based on the length of each citizen's residence violate the Equal Protection Clause of the Fourteenth Amendment?
Opinions:
Majority - Chief Justice Burger
Yes, the Alaska dividend distribution plan violates the guarantees of the Equal Protection Clause of the Fourteenth Amendment. The statute creates fixed, permanent distinctions between classes of bona fide residents based solely on how long they have lived in the state, which is not rationally related to a legitimate state purpose. The Court rejected Alaska's three proffered justifications: 1) creating a financial incentive to maintain residence is not served by retroactively rewarding past residency; 2) encouraging prudent management of the Fund is not rationally served by the retrospective dividend scheme; and 3) rewarding citizens for past contributions is not a legitimate state purpose. Citing Shapiro v. Thompson, the Court held that the Equal Protection Clause prohibits apportioning state services and benefits based on past contributions, as it would permit states to divide citizens into an expanding number of permanent classes, which is impermissible.
Dissenting - Justice Rehnquist
No, the Alaska distribution scheme does not violate the Equal Protection Clause. The scheme is a form of economic regulation that is presumptively valid and should be upheld if it is rationally related to a legitimate state interest. The Court improperly dismisses Alaska's goal of rewarding citizens for past contributions by relying on right-to-travel cases, which the majority concedes do not apply with their strict scrutiny standard here. Rewarding residents who have endured the hardships of living in Alaska and contributed to the state over a longer period is a rational basis for the classification. The Court's decision oversteps its role by imposing its own view of wise economic policy on the state.
Concurring - Justice Brennan
Yes, the Alaska law is unconstitutional, but for reasons beyond just the Equal Protection Clause analysis. The scheme infringes upon the federally protected right to travel and migrate between states, which is fundamental to the nation's structure. If states could reward citizens incrementally for years of residence, it would penalize mobility and undermine the Union. Furthermore, the Citizenship Clause of the Fourteenth Amendment implies a single, equal status of citizenship within a state, which prohibits creating degrees of citizenship based on length of residence. Discrimination based on length of residence is almost always premised on the unconstitutional idea that 'some citizens are more equal than others.'
Concurring - Justice O'Connor
Yes, the law is unconstitutional, but the Court's analysis is misdirected. Instead of declaring the state's purpose of rewarding past contributions 'illegitimate' under the Equal Protection Clause, the proper analysis rests on the Privileges and Immunities Clause of Article IV. This clause was designed to ensure that a citizen of one state who moves to another enjoys the same privileges as the citizens of that new state. Alaska's scheme violates this principle by creating a permanent, inferior class of citizenship for newer residents, thereby imposing one of the 'disabilities of alienage' that the Clause prohibits. This approach provides a more solid constitutional foundation for protecting the right to travel.
Analysis:
This case establishes a significant limit on a state's ability to apportion benefits based on residency duration. By declaring that 'rewarding past contributions' is not a legitimate state purpose for such a classification, the Court strongly reinforces the principle of equal citizenship for all bona fide residents of a state, regardless of when they arrived. The decision prevents states from creating a seniority system for public benefits, which could penalize interstate migration. While the majority opinion rests on rational basis review, the concurrences from Justices Brennan and O'Connor highlight that such laws also implicate more fundamental constitutional principles, including the right to travel and the Privileges and Immunities Clause, signaling that durational residency classifications will face high constitutional scrutiny.
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