Rodriguez v. United States

169 F.3d 1342 (11th Cir. 1999) ; Clearinghouse Number: 52219

Description

Welfare Act Provisions Terminating Supplemental Security Income and Food Stamps to Some Legal Aliens Are Upheld

Abstract

Affirming, the Eleventh Circuit upheld a provision of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 that provides that only 14 specified categories of aliens remain eligible for Supplemental Security Income , food stamps, or both. Plaintiff-appellants, a class of poor, elderly, and disabled aliens who were legally residing in Florida before the welfare act was enacted and who do not fit within any of the eligible categories, argued that the statute violated their Fifth Amendment right to equal protection. After determining that Mathews v. Diaz, 426 U.S. 67 (1976), dictated the application of the rational basis test, the district court concluded that the challenged provision was constitutional and dismissed plaintiffs’ claim. On appeal, plaintiff-appellants argued that the district court should have applied a heightened level of scrutiny and that, even if the rational basis test were applicable, the district court erred in concluding that the provision satisfied that test. The court of appeals determined that under Mathews the rational basis test was appropriate for Fifth Amendment challenges to classification of aliens. Rejecting plaintiff-appellants’ argument that cost savings was not a legitimate interest for Congress to pursue under its sovereign immigration power, the court held that Congress’ decision to reduce the number of aliens eligible for Supplemental Security Income and food stamps by providing that only the aliens in the 14 categories specified in the challenged provision were eligible for those benefits was rationally related to the legitimate purpose of reducing the cost of those welfare programs. None of the fourteen eligible categories Congress established, nor imposing a cutoff date for eligibility within those categories, was wholly irrational.

Additional Information

Attorney Information
Plaintiff-appellants represented by JoNel Newman, Florida Justice Institute, 2870 1st Union Financial Center, 200 S. Biscayne Blvd., Miami, FL 33131; 305.358.2081.
Docket Date
1970-01-01 06:00:00+00:00