Califano v. Aznavorian, 439 U.S. 170 (1978), was a United States Supreme Court case involving denial of Social Security Benefits to recipients while they are abroad and the Fifth Amendment due process right to international travel.

[1] The Supplemental Security Income (SSI) program was enacted by Congress in 1972 to aid needy aged, blind, and disabled people.

Justice Stewart delivered the opinion of the Court, holding, without dissent, that Section 1611(f) of the Social Security Act was constitutional because it had a rational basis and did not impose an impermissible burden on the freedom of international travel in violation of the Fifth Amendment because the section merely had an incidental effect on international travel, (distinguishing Kent v. Dulles,[3] Aptheker v. Secretary of State,[4] and Zemel v.

The Court rejected Aznavorian's assertion that because the statutory provision of § 1611(f)limits the freedom of international travel, a more stringent standard must be applied in its constitutional appraisal.

The Court noted that legislation providing governmental payments of monetary benefits here had an incidental effect on a protected liberty and it did not have nearly so direct an impact on the freedom to travel internationally as occurred in the Kent, Aptheker, or Zemel.

[6] Therefore, they did not understand the Court to imply that welfare legislation not involving a fundamental interest or suspect classification is subject to a lesser standard of review than the traditional rational basis test.