In the case of Vlandis v. Kline et al., 1972, the U.S. Supreme Court ruled that a Connecticut law which classified students as in-state or out-of-state for tuition purposes based on their residence at the time of application was unconstitutional. The court found this to be an irrebuttable presumption that violated due process rights under the Fourteenth Amendment because it did not allow students to present evidence showing they had become residents after applying but before attending school. The state argued that this policy was necessary for administrative convenience and budget predictability, however, these reasons were deemed insufficient by the court to justify denying individuals their constitutional right to challenge their classification.

In the dissenting opinion for Vlandis v. Kline, Justice William Rehnquist argued that the majority's decision to strike down Connecticut's residency requirement for in-state tuition at its public universities was an overreach of judicial authority. He contended that it is not within the purview of courts to decide on matters related to state policies unless they are clearly unconstitutional. The justice believed that there were rational reasons behind Connecticut’s policy, such as ensuring those who contribute more towards supporting public institutions through taxes receive benefits and preventing students from other states taking advantage of lower tuition rates without contributing significantly to state revenues. Furthermore, he pointed out that many other states had similar laws and suggested this ruling could have far-reaching implications beyond just Connecticut.