Graham v. Richardson

Arizona participated in an assistance program funded in part by federal grants and administered by Arizona under federal guidelines. In addition to the federal requirements, Arizona required that program beneficiaries be United States citizens or have resided in the United States for at least fifteen years. Similarly, Pennsylvania funded its own welfare program, but only United States citizens were permitted to receive benefits. Carmen Richardson (plaintiff) was a lawfully admitted resident alien in Arizona who was denied program benefits solely because she did not meet Arizona’s residency requirement. Elsie Leger (plaintiff) was a lawfully admitted resident alien in Pennsylvania who was denied assistance due to her lack of citizenship. Richardson and Leger brought separate class action suits against Graham (defendant), the Commissioner of the Arizona Department of Public Welfare, the Executive Director of the Philadelphia County Board of Assistance, and the Secretary of the Commonwealth’s Department of Public Welfare (defendants), respectively. The plaintiffs argued that the residency and citizenship requirements violated the Equal Protection Clause of the Fourteenth Amendment. The Arizona district court granted Richardson summary judgment on equal protection grounds, and Graham appealed. Leger was granted a temporary restraining order and began receiving assistance, and the defendants appealed. The cases were consolidated before the United States Supreme Court.