7th Circuit: PRWORA Restrictions on Eligibility for Benefits Constitutional (City of Chicago, et al. v. Shalala et al.)

IMMIGRANTS & PUBLIC BENEFITS

Food and Nutrition Programs

7TH CIRCUIT: PRWORA RESTRICTIONS ON ELIGIBILITY FOR BENEFITS CONSTITUTIONAL (CITY OF CHICAGO, ET AL. V. SHALALA, ET AL.)
Immigrants' Rights Update, Vol. 13, No. 6, October 13, 1999

The Seventh Circuit Court of Appeals has found that provisions in the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) that limit immigrant eligibility for food stamps, Supplemental Security Income (SSI), and other welfare benefits do not violate the equal protection component of the Fifth Amendment’s Due Process Clause.

The City of Chicago and several city officials brought suit against the secretary of the U.S. Dept. of Health and Human Services and other federal officers on behalf of immigrants whose access to public benefits was restricted by the PRWORA. Subsequently, a number of legal permanent residents (LPRs) and an organization of ethnic associations with LPR members intervened and sought class certification.

Ultimately, in addition to the original plaintiffs, two classes of plaintiffs were certified. The first included Illinois residents who are LPRs and who had their SSI benefits terminated or a claim for SSI benefits denied after Aug. 22, 1996. The second consisted of Illinois residents who are LPRs and who, after Aug. 22, 1996, received, applied for, or will apply for food stamps, Temporary Assistance to Needy Families, Medicaid, or Social Services Block Grants, and who have had or will have their benefits terminated or their applications denied.

In response to the plaintiffs’ allegations that the provisions of the PRWORA disqualifying legal immigrants from receiving federal welfare benefits violate the Fifth Amendment’s Due Process Clause, the defendants filed motions to dismiss their complaints. After the district court granted the defendants’ motions, the plaintiffs appealed.

In affirming the lower court’s ruling, the Seventh Circuit declined to provide heightened scrutiny to the PRWORA provisions contested by the plaintiffs’ equal protection claim. Instead, the court adopted the deferential “rational basis” standard, under which a statute is considered constitutional if it is rationally related to a legitimate governmental purpose. The court concluded that because the PRWORA provisions at issue have a legitimate purpose—encouraging immigrants’ self-sufficiency—and are reasonably related to that purpose, the statute is constitutional.

City of Chicago, et al. v. Shalala et al.,No. 982382 1999 U.S. App. LEXIS 20885 (7th Cir. Aug. 31, 1999).