Lexplug logoLexplug

Mathews v. Diaz

Supreme Court of United States
426 U.S. 67 (1976)
ELI5:

Rule of Law:

Federal laws that condition an alien's eligibility for welfare benefits on citizenship status, legal status, and duration of residency are subject to a deferential standard of review and do not violate the Due Process Clause of the Fifth Amendment if they are not wholly irrational.


Facts:

  • Appellees Diaz and Clara are elderly Cuban refugees who were lawfully present in the United States for less than five years but had not been admitted for permanent residence.
  • Appellee Espinosa is an elderly alien who was lawfully admitted for permanent residence but had resided in the United States for less than five years.
  • A federal statute, 42 U.S.C. § 1395o(2), establishes eligibility requirements for the Medicare Part B supplemental medical insurance program.
  • The statute grants eligibility to United States citizens who are 65 or older.
  • For aliens to be eligible, the statute requires them to be 65 or older, lawfully admitted for permanent residence, and have resided in the United States continuously for at least five years.
  • Diaz and Clara were denied enrollment in the Medicare Part B program for failing to meet either the permanent residence or the five-year residency requirement.
  • Espinosa was ineligible for enrollment because he could not meet the five-year residency requirement, despite being a permanent resident.

Procedural Posture:

  • Diaz, Clara, and Espinosa (appellees) filed a class action lawsuit against the Secretary of Health, Education, and Welfare (appellant) in the U.S. District Court for the Southern District of Florida.
  • The complaint sought a declaration that the Medicare eligibility requirements for aliens were unconstitutional and an injunction against their enforcement.
  • A three-judge District Court was convened to hear the case.
  • The District Court granted summary judgment for the plaintiffs, holding that the five-year residency requirement violated the Due Process Clause of the Fifth Amendment.
  • The District Court also found the residency requirement was not severable from the permanent residence requirement, thus invalidating the entire alien eligibility provision.
  • The Secretary was enjoined from enforcing the statutory requirements against the plaintiffs.
  • The Secretary filed a direct appeal to the Supreme Court of the United States.

Locked

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does a federal statute that conditions an alien's eligibility for the Medicare Part B insurance program on being lawfully admitted for permanent residence and residing in the United States for at least five years violate the Due Process Clause of the Fifth Amendment?


Opinions:

Majority - Mr. Justice Stevens

No. The federal statute conditioning an alien's eligibility for Medicare Part B on permanent residence status and a five-year residency period does not violate the Due Process Clause of the Fifth Amendment. The Court reasoned that regulating the relationship between the United States and aliens is a responsibility committed to the political branches of the federal government, not the judiciary. Unlike states, Congress has broad power over immigration and naturalization, allowing it to create rules for aliens that would be unacceptable if applied to citizens. Therefore, judicial review of such classifications is narrow. The Court found it was not irrational for Congress to make an alien's eligibility depend on the character and duration of their residence, as these factors can reasonably be presumed to reflect a greater affinity with the United States. The decision distinguished cases like Graham v. Richardson, which applied strict scrutiny to state laws classifying aliens, by emphasizing the unique and plenary power of the federal government in this area.



Analysis:

This decision establishes a crucial distinction between the powers of state governments and the federal government in regulating aliens. It creates a two-tiered system of judicial review for alienage classifications: while state laws are subject to strict scrutiny under the Equal Protection Clause, federal laws are subject to a highly deferential rational basis review under the Fifth Amendment's Due Process Clause. This deference gives Congress significant latitude to create complex eligibility rules for federal benefits based on immigration status and duration of residence. The ruling solidifies the principle that immigration and naturalization are fundamentally matters of federal policy, largely immune from judicial interference unless a classification is wholly arbitrary.

G

Gunnerbot

AI-powered case assistant

Loaded: Mathews v. Diaz (1976)

Try: "What was the holding?" or "Explain the dissent"