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18 Urb. L. Ann. 197 (1980)
Residency Requirments for City Employees: Important Incentives in Today's Urban Crisis

handle is hein.journals/waucl18 and id is 201 raw text is: RESIDENCY REQUIREMENTS FOR CITY
EMPLOYEES: IMPORTANT INCENTIVES
IN TODAY'S URBAN CRISIS
Connie M. Hager*
Two hundred years after colonization, the United States continues
to be a remarkably mobile society. Migration patterns, as well as
public reaction to the gasoline shortage, make it apparent that Ameri-
cans appreciate and cherish their right to travel throughout the coun-
try. This constant redistribution of the population is far from
random, however. While demonstrating the so-called right each
person has to live where he chooses, Americans are abandoning the
central cities in ever-increasing numbers.'
Since free movement of persons has developed into a constitution-
ally protected fundamental right to travel,' few legal restrictions may
Attorney, Team Four, Inc., St. Louis, Mo.; B.A., University of Missouri at St.
Louis, 1976., J.D., Washington University, 1979.
1. According to statistics, Americans no longer wish to live in the central cities but
prefer suburbia. During the 1960's, the central cities gained 5.3% in population while
the surrounding areas grew by 28.2%. Only the population of nine of the 20 largest
cities increased during the decade. Except for New York, which showed a 1% gain,
all of the major cities of the North and East lost more residents than they added. For
a fine summary of this trend, see Costello, The Future of the City in EDITORIAL RE-
SEARCH REPORTS ON THE FUTURE OF THE CITY 3-7 (1974).
2  Although the courts have recognized a constitutional right to travel for many
years, the source of that right remains unclear. In the Passengers Cases, 48 U.S. (7
How.) 283 (1849), the Supreme Court traced the right to the commerce clause; in
Ward v. Maryland, 789 U.S. (12 Wall.) 418 (1870), to the privileges and immunities
clause: in Kent v. Dulles, 357 U.S. 116 (1958) to the Fifth Amendment; and to no
particular constitutional provision in Shapiro v. Thompson, 394 U.S. 618 (1969). For

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