The Wheeler v. Montgomery case in 1969 revolved around the constitutionality of a California law that required welfare recipients to pick up their checks personally at designated offices, rather than having them mailed directly. The plaintiffs, who were all disabled and found it difficult or impossible to travel due to their conditions, argued that this requirement violated the Equal Protection Clause of the Fourteenth Amendment by discriminating against those with disabilities. They also contended that it infringed upon their rights under the First and Ninth Amendments by interfering with personal privacy and freedom of movement. However, the Supreme Court ruled against them in a per curiam decision (a ruling issued collectively by multiple judges), stating that there was no constitutional right for welfare recipients to receive payments through mail delivery. The court held that states have broad discretion over how they administer public assistance programs as long as they do not violate specific federal laws or regulations. Therefore, requiring beneficiaries to collect checks personally did not constitute discrimination under equal protection principles because everyone was treated equally regardless of disability status.

In the dissenting opinion for Wheeler et al. v. Montgomery, Justice Harlan argued that the majority's decision to strike down California's residency requirement for welfare benefits was misguided and overreached their judicial authority. He contended that states should have the right to determine their own policies regarding public assistance without interference from federal courts unless there is a clear violation of constitutional rights. In this case, he did not believe such a violation existed as states have legitimate interests in preserving resources and preventing fraud which could justify imposing certain restrictions on eligibility for welfare benefits like residency requirements. Furthermore, he expressed concern about potential negative consequences of eliminating these types of regulations including increased burdens on taxpayers and possible disincentives for individuals to seek employment or improve their economic circumstances.