Summary of Saenz v. Roe and the Impact on Welfare Reciepients
In an effort to lower their welfare expenditures, California enacted a law to restructure benefits paid to families under the Aid to Families with Dependent Children (AFDC) program. Under the new law, enacted in 1992, AFDC applicants that had resided in California for less than one year would receive benefits at the level paid in their previous state if that amount was lower than the California benefit payment. (Cal. Welf. & Inst. Code Ann. S11450.03. Because the law effected benefits paid under a federal program, the state was required to secure a waiver from the Secretary of Health and Human Services. The Secretary granted the waiver, but before the policy was implemented, two lawsuits were brought challenging various aspects of the welfare reform law. One of these cases, Beno v. Shalala, 30 F.3d 1057 (9th Cir. 1994), resulted in nullification of the waiver. The other case, Green v. Anderson, 811 F. Supp. 516 (E.D.Cal. 1993), aff'd, 26 F.3d 95 (9th Cir. 1994), resulted in an injunction to prevent the state from implementing the tiered benefits based on residency on the grounds that it violated the constitutional right to travel. This was affirmed by the Court of Appeals, and the Supreme Court granted certiorari. However
After the repeal of AFDC, and the passage of the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) in 1996, California was no longer required to obtain a waiver on the residency policy. The state announced that it would begin implementation of the 1992 law. Once again, new residents to the state who would receive much lower welfare benefits as a result of the policy filed suit in Roe v. Anderson. The district court held that the residency requirement was unconstitutional. The Ninth Circuit again affirmed the decision, and the State again filed a petition for certiorari. At issue in this case was the constitutionality of a state limiting the welfare benefits of new residents. The plaintiffs held that limiting their benefits based on their previous residency violated their constitutional right to travel. California held that they had a right to determine at what level benefits were paid, in an effort to control their own funds and save the taxpayers money. Dissenting opinions were written by Justice Thomas and Chief Justice Rehnquist, and each joined in the others dissent. In his dissenting opinion, Chief Justice Rehnquist holds that the right to travel and the right to become a resident of another state
Some common words found in the essay are:
Fourteenth Amendment, Ninth Circuit, Justice Rehnquist, Green Anderson, Citizens United, Act PRWORA, Children AFDC, Justice Stevens, Supreme Court, Services Secretary, benefits paid, benefits based, level benefits, chief justice rehnquist, privileges immunities clause, cost living, privileges immunities, chief justice, immunities clause, 9th cir 1994, fourteenth amendment, violated constitutional travel, justice stevens, cir 1994 resulted, 9th cir,
Approximate Word count = 839
Approximate Pages = 3 (250 words per page double spaced)
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