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The Memorial Hospital v. Maricopa County case in 1973 revolved around an Arizona law that required a year's residency in a county before non-emergency hospitalization expenses could be covered at public expense. The Supreme Court ruled this law as unconstitutional, violating the Equal Protection Clause of the Fourteenth Amendment. The court found that while states have the right to regulate benefits and ensure they are not taken advantage of by transient citizens, imposing a one-year waiting period was too harsh and unnecessary for achieving these objectives. This decision emphasized that conditions on which people would receive basic needs like medical care should not infringe upon their constitutional rights or discriminate against them based on their financial status or length of residency.
In the dissenting opinion for Memorial Hospital v. Maricopa County, Justice Rehnquist disagreed with the majority's view that Arizona’s one-year residency requirement for non-emergency medical care was unconstitutional. He argued that this decision disregarded previous rulings which upheld states' rights to impose reasonable residency requirements for benefits. He contended that such requirements were not inherently discriminatory and served a legitimate state interest by ensuring resources are allocated to long-term residents who have contributed more significantly to public funds through taxes over time. Furthermore, he criticized the Court's use of strict scrutiny in evaluating these laws as it traditionally applied only in cases involving fundamental rights or suspect classifications, neither of which he believed were applicable here. Lastly, he expressed concern about potential consequences of this ruling on other state welfare programs with similar residency conditions.