In the case of New York Civil Service Commission et al. v. Snead (1975), the U.S Supreme Court ruled in favor of the New York Civil Service Commission, upholding a state law that required public employees to live within their employment jurisdiction as a condition for continued employment. The plaintiff, Barbara Snead, was an employee at Creedmoor Psychiatric Center who moved outside her work's geographical jurisdiction and subsequently lost her job due to non-compliance with this residency requirement. She argued that this violated her constitutional rights under both Equal Protection and Due Process Clauses by restricting freedom of movement across state lines without sufficient justification from the State. The court disagreed with Snead’s argument stating that such requirements were not unconstitutional because they served legitimate governmental interests including promoting ethnic balance in communities and ensuring availability during emergencies among other reasons provided by the State. Therefore, it concluded that while there might be some burden on interstate migration imposed by these rules, it did not outweigh these valid government interests hence no violation occurred.

In the dissenting opinion for New York Civil Service Commission v. Snead, Justice Brennan argued that the majority's decision was inconsistent with previous rulings on equal protection claims. He contended that the court had previously held that a state must show some rational basis for its discriminatory action and demonstrate how it furthers a legitimate state interest. In this case, he believed New York failed to meet this standard by not providing any evidence of how denying unemployment benefits to striking public employees served a valid governmental purpose or promoted labor peace in any significant way. Furthermore, he criticized the majority's reliance on an "unsupported assumption" about potential violence during strikes as justification for discrimination against strikers. He concluded his dissent by stating that without substantial proof from New York justifying their actions, they should be deemed unconstitutional under Equal Protection Clause standards.