In the case of Edward McNamara v. County of San Diego Department of Social Services in 1988, Edward McNamara challenged the constitutionality of a California statute that allowed for involuntary commitment and treatment for individuals suffering from chronic alcoholism. The Supreme Court declined to review the case, thereby upholding lower court rulings which found that such commitments did not violate an individual's constitutional rights. This decision effectively affirmed California's ability to involuntarily commit and treat chronic alcoholics under certain conditions without infringing upon their civil liberties as protected by the U.S Constitution.

The dissenting opinion in the case of McNamara v. County of San Diego Department of Social Services argued that the majority's decision to uphold a California law requiring welfare applicants to live in the state for at least one year before becoming eligible for benefits was misguided. The dissenters believed this residency requirement violated the Equal Protection Clause, as it discriminated against new residents based on their length of residence alone, without any substantial justification from the state. They also disagreed with the majority's assertion that such discrimination could be justified by budgetary concerns or fear of becoming a "welfare magnet." Furthermore, they contended that this ruling undermined previous Supreme Court decisions which had established strict scrutiny as an appropriate standard for evaluating laws infringing upon fundamental rights and liberties - including freedom to travel between states.