Sosna v. Iowa

Mr. Justice Marshall, with whom Mr. Justice Brennan joins,

dissenting.

The Court today departs sharply from the course we have followed in analyzing durational residency requirements since Shapiro v. Thompson, 394 U. S. 618 (1969). Because I think the principles set out in that case and its progeny compel reversal here, I respectfully dissent.

As we have made clear in Shapiro and subsequent cases, any classification that penalizes exercise of the constitutional right to travel is invalid unless it is justified by a compelling governmental interest. As recently as last Term we held that the right to travel requires that States provide the same vital governmental benefits and privileges to recent immigrants that they do to longtime residents. Memorial Hospital v. Maricopa County, 415 U. S. 250, 261 (1974). Although we recognized that not all durational residency requirements are penalties *419upon the exercise of the right to travel interstate,1 we held that free medical aid, like voting, see Dunn v. Blumstein, 405 U. S. 330 (1972), and welfare assistance, see Shapiro v. Thompson, supra, was of such fundamental importance that the State could not constitutionally condition its receipt upon long-term residence. After examining Arizona’s justifications for restricting the availability of free medical services, we concluded that the State had failed to show that in pursuing legitimate objectives it had chosen means that did not impinge unnecessarily upon constitutionally protected interests.

The Court’s failure to address the instant case in these terms suggests a new distaste for the mode of analysis we have applied to this corner of equal protection law. In its stead, the Court has employed what appears to be an ad hoc balancing test, under which the State’s putative interest in ensuring that its divorce petitioners establish some roots in Iowa is said to justify the one-year residency requirement. I am concerned not only about the disposition of this case, but also about the implications of the majority’s analysis for other divorce statutes and for durational residency requirement cases in general.

I

The Court omits altogether what should be the first inquiry: whether the right to obtain a divorce is of sufficient importance that its denial to recent immigrants constitutes a penalty on interstate travel. In my view, it clearly meets that standard. The previous decisions of this Court make it plain that the right of marital association is one of the most basic rights conferred on the individual by the State. The interests associated *420with marriage and divorce have repeatedly been accorded particular deference, and the right to marry has been termed “one of the vital personal rights essential to the orderly pursuit of happiness by free men.” Loving v. Virginia, 388 U. S. 1, 12 (1967). In Boddie v. Connecticut, 401 U. S. 371 (1971), we recognized that the right to seek dissolution of the marital relationship was closely related to the right to marry, as both involve the voluntary adjustment of the same fundamental human relationship. Id., at 383. Without further laboring the point, I think it is clear beyond cavil that the right to seek dissolution of the marital relationship is of such fundamental importance that denial of this right to the class of recent interstate travelers penalizes interstate travel within the meaning of Shapiro, Dunn, and Maricopa County.

II

Having determined that the interest in obtaining a divorce is of substantial social importance, I would scrutinize Iowa’s durational residency requirement to determine whether it constitutes a reasonable means of furthering important interests asserted by the State. The Court, however, has not only declined to apply the “compelling interest” test to this case, it has conjured up possible justifications for the State’s restriction in a manner much more akin to the lenient standard we have in the past applied in analyzing equal protection challenges to business regulations. See McGowan v. Maryland, 366 U. S. 420, 425-428 (1961); Kotch v. Board of River Port Pilot Comm’rs, 330 U. S. 552, 557 (1947); but see Johnson v. Robison, 415 U. S. 361, 376 (1974). I continue to be of the view that the “rational basis” test has no place in equal protection analysis when important individual interests with constitutional implications are at stake, see San Antonio School District v. Rodriguez, 411 *421U. S. 1, 109 (1973) (Marshall, J., dissenting); Dandridge v. Williams, 397 U. S. 471, 520-522 (1970) (Marshall, J., dissenting). But whatever the ultimate resting point of the current readjustments in equal protection analysis, the Court has clearly directed that the proper standard to apply to cases in which state statutes have penalized the exercise of the right to interstate travel is the “compelling interest” test. Shapiro v. Thompson, 394 U. S., at 634, 638; Oregon v. Mitchell, 400 U. S. 112, 238 (1970) (opinion of Brennan, White, and Marshall, JJ.); Dunn v. Blumstein, 405 U. S., at 342-343; Memorial Hospital v. Maricopa County, 415 U. S., at 262-263.

The Court proposes three defenses for the Iowa statute: first, the residency requirement merely delays receipt of the benefit in question — it does not deprive the applicant of the benefit altogether; second, since significant social consequences may follow from the conferral of a divorce, the State may legitimately regulate the divorce process; and third, the State has interests both in protecting itself from use as a “divorce mill” and in protecting its judgments from possible collateral attack in other States. In my view, the first two defenses provide no significant support for the statute in question here. Only the third has any real force.

A

With the first justification, the Court seeks to distinguish the Shapiro, Dunn, and Maricopa County cases. Yet the distinction the Court draws seems to me specious. Iowa’s residency requirement, the Court says, merely forestalls access to the courts; applicants seeking welfare payments, medical aid, and the right to vote, on the other hand, suffer unrecoverable losses throughout the waiting period. This analysis, however, ignores the severity of the deprivation suffered by the divorce petitioner who is forced to wait a year for relief. See Stanley v. Illinois, *422405 U. S. 645, 647 (1972). The injury accompanying that delay is not directly measurable in money terms like the loss of welfare benefits, but it cannot reasonably be argued that when the year has elapsed, the petitioner is made whole. The year’s wait prevents remarriage and locks both partners into what may be an intolerable, destructive relationship. Even applying the Court’s argument on its own terms, I fail to see how the Maricopa County case can be distinguished. A potential patient may well need treatment for a single ailment. Under Arizona statutes he would have had to wait a year before he could be treated. Yet the majority’s analysis would suggest that Mr. Evaro’s claim for nonemergency medical aid is not cognizable because he would “eventually qualify for the same sort of [service],” ante, at 406. The Court cannot mean that Mrs. Sosna has not suffered any injury by being foreclosed from seeking a divorce in Iowa for a year. It must instead mean that it does not regard that deprivation as being very severe.2

B

1 find the majority’s second argument no more persuasive. The Court forgoes reliance on the usual justifications for durational residency requirements — budgetary considerations and administrative convenience, see Shapiro, 394 U. S., at 627-638; Maricopa County, 415 U. S., at 262-269. Indeed, it would be hard to make a persuasive argument that either of these interests is significantly *423implicated in this case. In their place, the majority invokes a more amorphous justification — the magnitude of the interests affected and resolved by a divorce proceeding. Certainly the stakes in a divorce are weighty both for the individuals directly involved in the adjudication and for others immediately affected by it. The critical importance of the divorce process, however, weakens the argument for a long residency requirement rather than strengthens it. The impact of the divorce decree only underscores the necessity that the State’s regulation be evenhanded.3

It is not enough to recite the State’s traditionally exclusive responsibility for regulating family law matters; some tangible interference with the State’s regulatory scheme must be shown. Yet in this ease, I fail to see how any legitimate objective of Iowa’s divorce regulations would be frustrated by granting equal access to new state residents.4 To draw on an analogy, the States have great interests in the local voting process and wide latitude in regulating that process. Yet one regulation that the States may not impose is an unduly long residency requirement. Dunn v. Blumstein, 405 U. S. 330 (1972). To remark, as the Court does, that because of the consequences riding on a divorce decree “Iowa may insist that one seeking to initiate such a proceeding have the modicum of attachment to the State required here” *424is not to make an argument, but merely to state the result.

C

The Court’s third justification seems to me the only one that warrants close consideration. Iowa has a legitimate interest in protecting itself against invasion by those seeking quick divorces in a forum with relatively lax divorce laws, and it may have some interest in avoiding collateral attacks on its decree in other States.5 These interests, however, would adequately be protected by a simple requirement of domicile — physical presence plus intent to remain — which would remove the rigid one-year barrier while permitting the State to restrict the availability of its divorce process to citizens who are genuinely its own.6

*425The majority notes that in Williams v. North Carolina, 325 U. S. 226 (1945), the Court held that for ex parte divorces one State’s finding of domicile could, under limited circumstances, be challenged in the courts of another. From this, the majority concludes that since Iowa’s findings of domicile' might be subject to collateral attack elsewhere, it should be permitted to cushion its findings with a one-year residency requirement.

For several reasons, the year’s waiting period seems to me neither necessary nor much of a cushion. First, the Williams opinion was not aimed at States seeking to avoid becoming divorce mills. Quite the opposite, it was rather plainly directed at States that had cultivated a “quickie divorce” reputation by playing fast and loose with findings of domicile. See id., at 236-237; id., at 241 (Murphy, J., concurring). If Iowa wishes to avoid becoming a haven for divorce seekers, it is inconceivable that its good-faith determinations of domicile would not meet the rather lenient full faith and credit standards set out in Williams.

A second problem with the majority’s argument on this score is that Williams applies only to ex parte divorces. This Court has held that if both spouses were before the divorcing court, a foreign Staté cannot recognize a collateral challenge that would not be permissible in the divorcing State. Sherrer v. Sherrer, 334 U. S. 343 (1948); Coe v. Coe, 334 U. S. 378 (1948); Johnson v. Muelberger, 340 U. S. 581 (1951); Cook v. Cook, 342 U. S. 126 (1951). Therefore, the Iowa statute sweeps too broadly even as a defense to possible collateral attacks, since it imposes a one-year requirement whenever the respondent does not reside in the State, regardless of whether the proceeding is ex parte 7

*426Third, even a one-year period does not provide complete protection against collateral attack. It merely makes it somewhat less likely that a second State will be able to find “cogent evidence” that Iowa’s determination of domicile was incorrect. But if the Iowa court has erroneously determined the question of domicile, the year’s residence will do nothing to preclude collateral attack under Williams.

Finally, in one sense the year’s residency requirement may technically increase rather than reduce the exposure of Iowa’s decrees to collateral attack. Iowa appears to be among the States that have interpreted their divorce residency requirements as being of jurisdictional import.8 Since a State’s divorce decree is subject to collateral challenge in a foreign forum for any jurisdictional flaw that would void it in the State’s own courts, New York ex rel. Halvey v. Halvey, 330 U. S. 610 (1947), the residency requirement exposes Iowa divorce proceedings to attack both for failure to prove domicile and for failure to prove one year’s residence. If nothing else, this casts doubt on the majority’s speculation that Iowa’s residency requirement may have been intended as a statutory shield for its divorce decrees. In sum, concerns about the need *427for a long residency requirement to defray collateral attacks on state judgments seem more fanciful than real. If, as the majority assumes, Iowa is interested in assuring itself that its divorce petitioners are legitimately Iowa citizens, requiring petitioners to provide convincing evidence of bona fide domicile should be more than adequate to the task.9

Ill

I conclude that the course Iowa has chosen in , restricting access to its divorce courts unduly interferes with the right to “migrate, resettle, find a new job, and start a new life.” Shapiro v. Thompson, 394 U. S., at 629. I would reverse the judgment of the District Court and remand for entry of an order granting relief if the court finds that there is a continuing controversy in this case. See Steffel v. Thompson, 415 U. S. 452 (1974); Johnson v. New York State Education Dept., 409 U. S. 75, 79 n. 7 (1972) (Marshall, J., concurring).

Memorial Hospital v. Maricopa County, 415 U. S., at 256-259; see also Shapiro v. Thompson, 394 U. S., at 638 n. 21.

The majority also relies on its "mere delay” distinction to dispose of Boddie v. Connecticut, 401 U. S. 371 (1971), see ante, at 410. Yet even though the majority in Boddie relied on due process rather than equal protection, I am fully convinced that if the Connecticut statute in question in that case had required indigents to wait a year for a divorce, the statute would still have been constitutionally infirm, see 401 U. S., at 383-386 (Douglas, J., concurring in result), a point the Court implicitly rejects today.

The majority identifies marital status, property rights, and custody and support arrangements as the important concerns commonly resolved by divorce proceedings. But by declining to exercise divorce jurisdiction over its new citizens, Iowa does not avoid affecting these weighty social concerns; instead, it freezes them in an unsatisfactory state that it would not require its long-time residents to endure.

A durational requirement such as Iowa’s 90-day conciliation period would not, of course, be subject to an equal protection challenge, as it is required uniformly of all divorce petitioners.

Appellees do not rely on these factors to support the Iowa statute. In their brief appellees argue that the legislature’s determination to impose a one-year residency requirement was reasonable “in the light of the interest of the State of Iowa in a dissolution proceeding.” Brief for Appellees 8. The full faith and credit argument is mentioned only in the middle of a long quotation from another court’s opinion, id., at 9. This is hardly sufficient to meet the requirement of a “clear showing that the burden imposed is necessary to protect a compelling and substantial governmental interest.” Oregon v. Mitchell, 400 U. S. 112, 238 (1970) (opinion of Brennan, White, and Marshall, JJ.); Sherbert v. Verner, 374 U. S. 398, 406-409 (1963).

The availability of a less restrictive alternative such as a domicile requirement weighs heavily in testing a challenged state regulation against the “compelling interest” standard. See Shapiro v. Thompson, 394 U. S., at 638; Dunn v. Blumstein, 405 U. S. 330, 342, 350-352 (1972); Memorial Hospital v. Maricopa County, 415 U. S., at 267; Shelton v. Tucker, 364 U. S. 479, 488 (1960). Since the Iowa courts have in effect interpreted the residency statute to require proof of domicile as well as one year’s residence, see Korsrud v. Korsrud, 242 Iowa 178, 45 N. W. 2d 848 (1951); Julson v. Julson, 255 Iowa 301, 122 N. W. 2d 329 (1963), a shift to a “pure” domicile test would impose no new burden on the State’s factfinding process.

This problem could be cured in large part if the State waived its year’s residency requirement whenever the respondent agreed to consent to the court’s jurisdiction.

See Hinds v. Hinds, 1 Iowa 36 (1855); Williamson v. Williamson, 179 Iowa 489, 495, 161 N. W. 482, 485 (1917); Korsrud v. Korsrud, supra; Schaefer v. Schaefer, 245 Iowa 1343, 1350, 66 N. W. 2d 428, 433 (1954); cf. White v. White, 138 Conn. 1, 81 A. 2d 450 (1951); Wyman v. Wyman, 212 N. W. 2d 368 (Minn. 1973); Camp v. Camp, 21 Misc. 2d 908, 189 N. Y. S. 2d 561 (1959) (construing Florida law). While the Williams case establishes that collateral attack can always be mounted against the divorcing State’s finding of domicile, other States have provided that failure to meet the durational residency requirement is not jurisdictional and thus does not provide an independent basis for collateral attack, see, e. g., Schreiner v. Schreiner, 502 S. W. 2d 840 (Tex. Ct. Civ. App. 1973); Hammond v. Hammond, 45 Wash. 2d 855, 278 P. 2d 387 (1954) (construing Idaho law).

The majority argues that since most States require a year’s residence for divorce, Iowa gains refuge from the risk of collateral attack in the understanding solicitude of States with similar laws. Of course, absent unusual circumstances, a judgment by this Court striking down the Iowa statute would similarly affect the other States with one- and two-year residency requirements. For the same reason, the risk of subjecting Iowa to an invasion of divorce seekers seems minimal. If long residency requirements are held unconstitutional, Iowa will not stand conspicuously alone without a residency requirement “defense.” Moreover, its 90-day conciliation period, required of aE divorce petitioners in the State, would stiH serve to discourage peripatetic divorce seekers who are looking for the quickest possible adjudication.