Memorial Hospital v. Maricopa County
1974 U.S. LEXIS 101, 415 U.S. 250, 39 L. Ed. 2d 306 (1974)
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Rule of Law:
A state law requiring a one-year period of county residency as a prerequisite to receiving free non-emergency medical care for indigents violates the Equal Protection Clause because it penalizes the fundamental right of interstate travel and is not justified by a compelling state interest.
Facts:
- Henry Evaro, an indigent individual, suffered from a chronic asthmatic and bronchial illness.
- In early June 1971, Evaro moved from New Mexico to Maricopa County, Arizona.
- On July 8, 1971, less than two months after moving, Evaro experienced a severe respiratory attack.
- An attending physician sent Evaro to Memorial Hospital, a private nonprofit community hospital, for treatment.
- An Arizona statute conditioned eligibility for free non-emergency county medical care on having been a resident of the county for the preceding twelve months.
- Memorial Hospital provided care to Evaro and requested reimbursement from Maricopa County.
- Maricopa County refused to reimburse the hospital or admit Evaro to its public facility, solely on the grounds that he had not satisfied the one-year residency requirement.
Procedural Posture:
- Memorial Hospital and Henry Evaro filed an action in an Arizona state trial court against Maricopa County.
- The trial court found the one-year residency requirement unconstitutional.
- Maricopa County, as appellant, appealed the decision to the Supreme Court of Arizona.
- The Supreme Court of Arizona, the state's highest court, reversed the trial court and upheld the statute.
- Memorial Hospital and Evaro, as appellants, appealed to the U.S. Supreme Court, which noted probable jurisdiction.
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Issue:
Does an Arizona statute that requires a one-year county residency as a condition for an indigent to receive free non-emergency medical care violate the Equal Protection Clause of the Fourteenth Amendment?
Opinions:
Majority - Justice Marshall
Yes. A durational residency requirement for receiving non-emergency indigent medical care violates the Equal Protection Clause. The Arizona statute creates a classification that penalizes the exercise of the fundamental right to migrate and settle in another state. Citing Shapiro v. Thompson, the Court reasoned that medical care is as much a 'basic necessity of life' to an indigent as welfare assistance. Therefore, the law must be judged by the strict scrutiny standard, requiring it to be necessary to promote a compelling state interest. The state's proffered interests—fiscal integrity, administrative convenience to determine bona fide residence, fraud prevention, and budget predictability—were all found to be not compelling. The Court concluded that a state may not protect its public fisc by drawing an invidious distinction between new and old residents, and less drastic means are available to achieve its administrative goals.
Concurring - Justice Douglas
Yes. While sharing doubts about the interstate travel analysis, the law is unconstitutional because it constitutes invidious discrimination against the poor. The durational residence requirement effectively fences poor people out of metropolitan counties like Maricopa that have adequate medical facilities. This discrimination, rather than the right to travel, is the critical issue. Additionally, he noted that Maricopa County had received federal Hill-Burton funds for hospital construction, which came with federal regulations requiring that facilities be available to all residents in the area, suggesting a conflict between the state law and federal policy.
Dissenting - Justice Rehnquist
No. The Arizona statute does not violate the Equal Protection Clause. There is no constitutional right to non-emergency medical care at state expense. The residency requirement does not create a real and purposeful barrier to travel; its effects are merely incidental and remote, unlike the laws struck down in cases like Shapiro. The Court wrongly extends the 'basic necessities of life' concept to non-emergency medical care. The state has a rational basis for its legislative choice, including the legitimate interests of allocating finite resources, promoting administrative objectives, and recognizing that longtime residents have a greater stake in capital facilities their past taxes helped to build. The Court should defer to the state legislature's difficult responsibility of allocating limited public funds.
Analysis:
This decision significantly expands the 'Shapiro' doctrine by classifying non-emergency medical care as a 'basic necessity of life,' akin to welfare benefits. It solidifies the application of strict scrutiny to any durational residency requirement that penalizes the right to interstate travel by withholding such necessities. The ruling limits a state's ability to conserve resources by distinguishing between new and old residents for essential government services. It forces states to find less restrictive means to verify residency or manage budgets, thereby strengthening protections for individuals who migrate between states.
