Washington Law Review




Vivian Marie Thompson, plaintiff, migrated from Boston, Massachusetts to Hartford, Connecticut to be near her mother. She arrived without prospect of specific employment or sufficient funds to maintain herself and her child while attempting to locate work. During her residency in Boston, she received financial support under a jointlyfunded state-federal program of Aid to Dependent Children (ADC). When she applied for similar assistance in Hartford her request was denied by defendant, Connecticut's Commissioner of Welfare, because she had not been a resident of the state for one year as required by Connecticut law. plaintiff brought suit in the United States District Court for the District of Connecticut seeking to have the residency requirement declared unconstitutional. The district court held: A one year residency requirement for categorical public assistance is invalid because it inhibits the exercise of the constitutionally protected right to travel, and alternatively, the protection of state funds is not a legitimate purpose for infringing upon the right to travel of a class of citizen possessing neither cash assets, probability of specific employment, nor residence of one year. Thompson v. Shapiro, 270 F. Supp. 331 (D. Conn. 1967) prob. juris. noted, 36 U.S.L.W. 3286 (U.S. Jan. 16, 1968).

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