In the case of Califano, Secretary of Health, Education, and Welfare v. Aznavorian (1978), the U.S. Supreme Court ruled that a provision in the Social Security Act did not violate an individual's constitutional rights to travel or equal protection under law. The provision in question reduced Supplemental Security Income (SSI) benefits for recipients who were outside of the United States for 30 consecutive days or more. Mrs. Aznavorian argued that this reduction violated her Fifth Amendment right to travel internationally without penalty and her Fourteenth Amendment right to equal protection as it discriminated against individuals based on their location abroad rather than their need for assistance. The court disagreed with these arguments stating that Congress had rational reasons for implementing this policy including administrative convenience and avoiding potential fraud from beneficiaries living overseas where monitoring is difficult. It also noted that SSI was designed specifically to assist those within U.S borders hence its limitation does not infringe upon any constitutional rights.

In the dissenting opinion for Califano v. Aznavorian, Justice Thurgood Marshall argued that the majority's decision was a misinterpretation of Section 1612(b) of the Social Security Act and its legislative history. He believed that Congress did not intend to penalize recipients who traveled outside of the United States but rather aimed to prevent individuals from collecting benefits while residing abroad permanently or indefinitely. The justice also expressed concerns about potential discrimination against lower-income beneficiaries who might need to travel internationally for family emergencies or other compelling reasons but would be deterred by fear of losing their benefits. Furthermore, he disagreed with the majority’s view on equal protection analysis, arguing that it failed to consider whether there was a rational basis for treating temporary absences differently based on duration alone.