free and unmolested travel

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The Right to Travel: A Fundamental Right of Citizenship

The right to travel within the United States is a fundamental right, existing before the creation of the United States and appearing in the Articles of Confederation. The right to travel is recognized and protected by the U.S. Constitution and the Supreme Court. This travel right entails privacy, leaving citizens free to travel interstate without government interference and intrusion. In the post-hijacking surveillance society, the imposition of official photo identification for travel, watch-list prescreening programs, and airport screening and search methods unreasonably burden the right to travel. They undermine citizens' rights to travel and privacy. These regulations impermissibly require citizens to relinquish one fundamental right of privacy in order to exercise another fundamental right of travel. The original conception of travel rights embodies the right as a broadly-based one that encompasses all modes of transportation. Its explicit articulation in the Articles of Confederation remains implicit in the Privileges and Immunities Clause of the U.S. Constitution. Contrary to arguments in the appellate single mode doctrine, if any mode of travel is abridged, then citizens' constitutionally enshrined right to travel is violated. The Supreme court needs to articulate an originally consistent and politically robust doctrine of the multi-modal right to travel.

• Find a library where document is available. Order URL: http://worldcat.org/oclc/31144651
• Sobel, Richard
• Torres, Ramon L
• Publication Date: 2013
• Media Type: Print
• Features: References;
• Pagination: pp 13-47
• Journal of Transportation Law, Logistics and Policy
• Issue Number: 1
• Publisher: Association for Transportation Law, Logistics and Policy
• ISSN: 1078-5906
• Serial URL: http://www.atlp.org/journal.html

Subject/Index Terms

• TRT Terms: Air travel ; Interstate transportation ; Legal rights ; Passenger handling ; Privacy ; Travel ; Travel modes
• Geographic Terms: United States
• Subject Areas: Aviation; Law; Passenger Transportation; I10: Economics and Administration;

Filing Info

• Accession Number: 01489821
• Record Type: Publication
• Files: TRIS
• Created Date: Aug 15 2013 9:13AM

Debunking sovereign citizens, freemen-on-the-land and other pseudo-legal theories.

Is there a right to travel without a driver's license in the united states.

Right to Travel vs. Freedom of Movement

The phrase "right to travel" should be clarified because it's commonly confused.

Many cases, documents, etc. using the phrase "right to travel" are in fact about Freedom of Movement , which is the Constitutional right to travel between States at will. If anyone speaks of a "Constitutional right to travel" Freedom of Movement is the only valid thing they could be referring to, as we'll show.

In pseudo-legal circles, "right to travel" means the supposed right to "travel freely in your private property / automobile / conveyance on the public roads / highways without a driver's license, insurance or registration and exempt from regulation or interruption provided one does not engage in commerce / earn profit or cause harm to people or property."

Absolute freedom! Could it be true? How does the law work?

Tenth Amendment, State Codes

Traffic regulation isn't mentioned in the Constitution, the supreme law of the land , therefore the power generally falls to the States pursuant to the 10th Amendment :

The powers not delegated to the United States by the Constitution, nor prohibited by it to the states, are reserved to the states respectively, or to the people.

States are free to enact whatever traffic regulations they want provided they do not violate federal law, as determined by the federal courts, pursuant to their police power .

All 50+ States, through their legislatures consisting of the people's elected representatives, have seen fit to devise and enact their own traffic codes and police them.

Was it always this way?

There wasn't always legislation displacing the common law. Automobile regulation began in the early 1900's. Here is an excellent paper that thoroughly explores the transitional period when decisions could go either way: The Orphaned Right: The Right to Travel by Automobile, 1890-1950 .

Bicycles were regulated decades before automobiles were invented and activists of the day faced many of the same questions and challenges modern right to travel proponents do. An analysis of that period can be found in this publication: The Impact of the Sport of Bicycle Riding on Safety Law .

Constitutionality

The States have all enacted traffic regulations, but do they violate federal law or the Constitution?

Judging constitutionality is ultimately up to the Supreme Court pursuant to Article 3:

The judicial power of the United States, shall be vested in one Supreme Court, and in such inferior courts as the Congress may from time to time ordain and establish.

Appeals are more-often-than-not declined by the Supreme Court so adjudication may stop at the federal United States Courts of Appeals (circuit courts) or District Courts and those are a good place to look for precedent, too. We prefer citations from these federal courts to avoid presumptions of bias that might arise by the State judging its own regulations and because federal decisions are superior to State decisions pursuant to the Supremacy Clause .

Federal Court Decisions

Let's have a look at some federal cases on the right of States to regulate traffic.

Hendrick v. Maryland 235 US 610 (1915)

The movement of motor vehicles over the highways is attended by constant and serious dangers to the public, and is also abnormally destructive to the ways themselves . . . In the absence of national legislation covering the subject a State may rightfully prescribe uniform regulations necessary for public safety and order in respect to the operation upon its highways of all motor vehicles — those moving in interstate commerce as well as others. And to this end it may require the registration of such vehicles and the licensing of their drivers . . . This is but an exercise of the police power uniformly recognized as belonging to the States and essential to the preservation of the health, safety and comfort of their citizens.

Hess v. Pawloski 274 US 352 (1927)

Motor vehicles are dangerous machines; and, even when skillfully and carefully operated, their use is attended by serious dangers to persons and property. In the public interest the State may make and enforce regulations reasonably calculated to promote care on the part of all, residents and non-residents alike, who use its highways.

Reitz v. Mealey 314 US 33 (1941)

The use of the public highways by motor vehicles, with its consequent dangers, renders the reasonableness and necessity of regulation apparent. The universal practice is to register ownership of automobiles and to license their drivers. Any appropriate means adopted by the states to insure competence and care on the part of its licensees and to protect others using the highway is consonant with due process.

There we have three solid federal Supreme Court decisions that set nationwide precedent that cannot be ignored. The Supreme Court is the final arbiter of law in the United States. Unless "right to travel" proponents can come up with a later Supreme Court ruling that states otherwise, their claims are busted.

And we have one less-impressive but telling quote from a lower federal district court:

Wells v. Malloy 402 F. Supp. 856 (1975)

Although a driver's license is an important property right in this age of the automobile, it does not follow that the right to drive is fundamental in the constitutional sense.

A few of the above cases were found in a somewhat inflammatory and dated but comprehensive publication, Idiot Legal Arguments . We picked out the relevant federal cases, but many more high-level State cases can be found there, too, if you're interested.

There actually isn't a whole lot at the federal level because appeals beyond State courts are often denied as it has long been accepted by the federal government that traffic regulation is a proper exercise of State police power. Federal courts uphold the ability of States to regulate road traffic provided it is done so with equality, reasonableness and for public safety and doesn't violate any federal laws or rights.

But I don't "drive" or use a "motor vehicle"! Those are legal terms used to enslave me and I'm smarter than that!

I'm afraid the State and its courts dictate how things are viewed under its law. You don't get to decide what's considered driving or a motor vehicle, they do. You can't simply switch out a few words to avoid responsibility. If you're in territory controlled by the US and/or a State then its laws may be applied to you and you have no lawful recourse (see Law Basics ).

I've heard of people being ignored or let go by police, even without a license or insurance!

Police have discretion . The world is a very dynamic place. There are any number of reasons why you might be passed by or allowed to proceed at any given time. The cop might be a scared rookie, not care, not want to fight, have a date, have to pee, be on lunch break, be at the end of their shift and going home – think about it – they're human, not machines. The priorities of police and prosecuting attorneys vary. The law is what it is, though, and when you understand it you know in the long run you're looking for trouble if you don't obey it.

I don't like traffic regulations. What can I do?

Your lawful remedy is to convince the majority of people in your State to put pressure on your elected representatives in the State legislature to change the law. That or you could move to another State or country where there are less regulations (and perhaps more fatalities ).

Study hard, verify claims, think for yourself, question this, comment.

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How to travel for free: the secret that no one tells you

Want to travel the world for free? I've been doing that for a long time. In this article, you'll get an in-depth view of what I do, how I do it, and how you can do it too!

Ayla Life in Lala's Land

Dec 19, 2023

Of course I have seen people all over Instagram and Facebook living these incredible lives, getting to see amazing places all over the world. I must confess I always thought this was fake or that they were all rich people. But since I came across the answers of how to travel for free (that no one told me) it completely transformed my life.

The purpose of this article is not to simply give you a list of the options you have to travel for free. You can find that on the internet anywhere.

I’m here to give you real life proof of how I already travel the world for free , since I’ve been travelling and living the nomadic life since July 2019. I'm crazily excited to share this, knowing just how much of an impact it can make to a person's life.

Some people get a little sceptical before they really get what I do , which I completely understand. If someone I didn’t know told me I could travel the world for free, I would probably think they were trying to scam me or something. But I didn’t have anyone tell me about it. I found it myself , and now I want to help others do the same.

I knew I wanted to travel and quit my job to do it . That would mean no money coming in - an exceptionally tight budget. So, I found a solution to the problem:  free food and accommodation !

In this article I’m going to walk you through how to do that. You can travel the world doing activities you love and get free accommodation - and even get paid to do it!

You might also like :  14 TOP cheapest countries to visit as a Worldpackers volunteer

Travelling for free: how it all started

One day I woke up and realised just how much I hated my daily life . I was working a ludicrous number of hours to get a great paycheck each week, but I was miserable. I decided that I had to take it into my own hands and create a life that I enjoyed living. And for me, that means new discoveries and environments.

In February of 2019 I handed in my resignation with 4 months’ notice. This was mainly for me to know I finally had a date I would be escaping the rat race. By July of that year, I was on a one-way flight to volunteer in India with a backpack and a suitcase with everything I owned in them.

When I said goodbye to all my friends and family, they knew that I had no intentions of ever returning to Australia or the life I was so eager to leave behind. 

I had no idea of what I was going to do, how I would be making money travelling or being able to survive, but it didn’t matter. All that mattered was that I had left behind a life that I didn’t want, in search of one that I loved.

It was then that I happened to stumble across the greatest life hack known to mankind – how to travel the world for free ! I have now been doing this and enjoying every moment of it.

I have the freedom to go anywhere I want in this world, and know that I am able to support myself. With a combination of these two life hacks that I will be speaking about here, I get almost all my food and accommodation paid for. 

I write for about two hours a day and I'm able to actually save a significant amount of money whilst I am travelling and experiencing the world.

How to travel for free: here's the secret

The number one best life hack that I have ever known is Worldpackers , hands down. 

Worldpackers is a platform that connects volunteers with certain skills or abilities to hosts who are looking for help in these areas. The method behind it is work exchange , where volunteers give their time helping out around the place in exchange for accommodation  and other benefits like meals, classes and tours.

It has provided me with numerous opportunities to travel through different countries on a tight budget, by not having to worry about accommodation and food. Not only that, but it has also given me an opportunity to build my name as an artist through both India and Sri Lanka .

As a girl who had a dream of travelling the world for free - with no idea of how to actually do it when I started - I am so lucky and grateful to have stumbled across Worldpackers!

Basically, you pay one fee of $49 USD which gives you access to all the hosts for a full year. To put that into perspective, $50 USD is likely A LOT less than you pay for one night of food and accommodation in most countries . And then you can spend 12 months with free accomodation and food wherever you want!

Seem’s crazy not to do it right? And what you give in exchange for the ability to travel for free, is often an experience you would be paying a hefty price for.  So really, it’s wins all around! You’re saving sooooo much money when you travel the world with Worldpackers.

Volunteer and travel for free

There are heaps of different options available when it comes to volunteer programs. So you’re sure to find something that calls to your heart. Some of them that I have chosen to work with are:

• Work in Schools
• Work on Eco projects
• Work with Hostel Administration 
• And primarily Art Projects

There are so many more options available , but these are the ones I have volunteered with so far. I typically look for art projects as I love painting. But other times I will apply for positions that pique my interest such as eco projects, because I am very much a save the world type of gal.

I have been very lucky to have had a range of volunteering experiences , mostly with painting. Mural painting is not something that I had ever even considered doing before.

I was so excited to do my first one and put my heart and soul into it, and surprisingly it was actually  not that bad. From there I was able to apply for more Worldpackers positions as an artist where I received free accommodation and all my meals for free.

This is a dream come true for someone who had been travelling for two months. I had no idea how to make any money and was just trying to spend as little as possible to stretch the money I did have as far as it could go. 

I’ve built great connections throughout communities doing this, and I’ve been asked to come back to a number of places, which is so heartwarming.

If you’re wondering how to travel for free, making an impact and giving more value to your contribution in this world , this is the secret. There are volunteer options that suit a range of different personality types and interests.

How to travel for free and also get paid

Although using Worldpackers covers almost all my expenses that I need to survive , there are still other things I need to pay for as I travel. Any flights, visas, sightseeing and going out with friends are costs that come out of my own pocket.

But someone I met at my first volunteer position provided me with a solution. I was only about two months into my travels at this point, when I explained to her my situation. She was blown away that I had no plan to balance working and travelling . In hindsight, it's a pretty crazy thing to do. Quit your job, pack your stuff and leave your own country without any means of income.

So, she introduced me to the world of  freelancing . This is something I had never heard about before then. She explained to me that there are many people that work remotely and get paid for it, which is what she does for a company she worked for back in Germany.

I told her that I wouldn’t be able to do it as I was absolutely terrible with technology and had no skills that would be of any value . She convinced me that I had everything I already needed: fluent English and a tablet I could write on.

She told me about some freelancing websites and I signed up to both Freelancer and Upwork . I then started applying for different positions but was not getting any luck. I had been trying for basic administration positions, which of course every other unskilled person was also applying for, so I was just getting lost in the masses.

Earlier in 2019 I had decided that I wanted to write a novel , which I am currently still working on, and this is something that I had shared with the girl who told me about freelancing. She saw me working on my novel all the time and motivated me to apply for some content writing positions . 

"The worst they could do is say no, and the best that can happen is you start getting paid to travel."

Eventually one company gave me a trial. Turns out they loved my writing style and offered me an ongoing position.

Becoming a digital nomad

The work I do could not be more perfect. It is incredibly flexible, I can ask for as much or as little work as I want, and it is something that I enjoy doing. 

I write content for businesses all over the world . Each piece might take me around 3 hours and will make me $50 USD. It’s not a lot, in fact, this job pays pretty terribly compared to the others I have now.

But depending on which part of the world I am, it pays for a LOT more than it would be back home. 

And I have such a different relationship with money than I did when working a ‘normal’ job. I am only interested in making enough money to cover my expenses from the previous month or to splurge on a vacation, such as a fancy resort somewhere.

Not only has securing a freelancing job been able to free me financially, it is such a different experience to be working on your own clock . Sometimes I might go a few days or a week without writing at all. Because I don’t have the need for money. But other times I might write for a full week and do nothing else. That is the beauty of freelancing.

Each week I decide how many projects I want, which generally is anywhere between two and 10. So that is a maximum of 30 hours a week if I really want to make some serious money, but I rarely have the need for that. So most times, I only work about 6 a week.

Combining this small amount of income with travelling the world for free with Worldpackers, I am able to save money while I’m travelling ! How crazy is that? I never would have thought that was possible.

An added benefit to freelancing is how much y ou learn about the potential of online work. I went from a non-tech savvy girl 15 months ago, to now having my own digital marketing agency . 

I do this by outsourcing all the work to the talented freelancers I’ve met along my journey . So whether you’ve got that business mind, or just want to work 5 hours a week to live as a digital nomad, it works for everyone.

Balancing freedom and motivation

When I was in Australia, I was a businesswoman. Always in a suit rushing around from meeting to meeting and under immense stress. Now I wouldn’t be recognisable to any of the people from my old position, or the clients that I worked with so closely. I am able to completely and freely express myself.

I now have blue hair and am starting to gather a collection of tattoos , and do you know what? It makes me so happy that I am able to live a life that is true to my own personality . Not to be living life restricted by the confines of society. But that doesn’t mean that I don’t have responsibilities.

I have the freedom to now travel where I want, dress (country-specific of course) and later my appearance as I please. And all I need to do is work about 5 hours a day to make that happen. So on average, I would spend 1 hour a day working and another 4 volunteering.

Although it can be tempting to run out with my friends as soon as the volunteering is done, I just give myself a reality check. It’s one hour. And if I schedule my time well, it makes little difference to my day, but a big difference to my life.

For me, I found setting out schedules works best for me. Mine looks something like this: yoga, breakfast, work, volunteer, lunch, write my novel, then free time. Sometimes I find myself creating stress out of nothing , but finding my balance with a schedule and yoga always helps me to keep motivated.

What in the world are you waiting for?

Yes, there is a legitimate way to travel the world for free and get paid, if that is the kind of life you want to live. I do it myself, and I’m just your average everyday person. Sometimes I realize how lucky I am to live this life, and then remember that luck had nothing to do with it . I found this out through research and took a leap of faith.

Seeing new countries and experiencing new cultures has been eye opening for me. And this is not something I would have been able to do for so long if I hadn’t stumbled across this life hack so early into my trip.

But luckily for everyone reading this, I have found them so that you don’t have to go searching . So now that you know how to travel for free, what are you waiting for? Go see the world! 

Join the community!

Create a free Worldpackers account to discover volunteer experiences perfect for you and get access to exclusive travel discounts!

Ayla Carlin

Life in Lala's Land

An Australian solo traveller who set out to find herself while discovering the world. My aim is to discover the untouched, make long lasting connections, and expand my mind through the new people I meet and places I discover. I want to inspire others through my experiences, showing just how important travel is for the soul, and how it can transform your life in the most positive ways.

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Write here your questions and greetings to the author

Oct 15, 2020

You're living the life, girl! As an author myself, that's pretty much a dream come true. Traveling and writing. Thank you for your words. I wish you all the success!

Oct 22, 2020

I wanna thanks you for your loyalty, and probably encourage you gave too all committee, thanks for who you are

Ayla (Author)

Nov 02, 2020

Thank you beautiful girl!! You also do the same??

Unfortunately, I don't. Right now, I just write in my home country. But I was published by a small publisher this year and I'm working on getting better to write on the road one day

Oct 19, 2020

Wow you're ao cool

Oct 20, 2020

Thank you beautiful people! Let's keep sharing our stories and welcoming more people to the traveling the world for free community!

Amazing text 🤍🤍 thanks for that

Oct 24, 2020

Good job👍👍💐💐

Feb 26, 2023

Amazing. Great job. Good Luck

Thank you ☺️

Oct 31, 2020

Thank you so much❤️

You are so welcome girl! ❤️❤️

Wooaaaaahhh 🤩🤩🤩🤩

Nov 06, 2020

Nov 08, 2020

It's great, I am cherishing the trip like you, currently I am looking for an online job to have money for the trip but I still haven't found it. Please guide and share your online work experience and your itinerary. Look forward to your guidance. My email: [email protected]

Nov 10, 2020

Thanks for sharing your experience.

Nov 11, 2020

Welcome Morocco

Nov 12, 2020

Super inspiring! :)

Nov 25, 2020

Hi Ayla, your story is very encouraging and motivational. I’m a newly certified Health and Life Coach, my dream is to work from anywhere, I got lost and confused, meanwhile I’m working part time as a professional organizer and decluttering, my dream is to travel so I decided enough of waiting to do it so I signed up here. But I’m interested in knowing more about your Marketing Biz, would like to talk to you about my business. Please could you reach out to me, [email protected] Thank You!!!

Nov 27, 2020

Well articulated

Dec 01, 2020

wow i like it thank you so much for sharing this

Dec 03, 2020

Thanks for your inspiring words, keep it up! :)

Cool with patient and courage

Wow, I really needed to hear this. I'd love to chat with you deeper since I have so many questions! How can I contact you? Do you have Instagram?

Dec 04, 2020

Hey Linda, I'd be happy to help 😊 My insta is lifein_lalasland

Sent you a message there!

Dec 08, 2020

Hi there, I admire your courage, wish i can do the same, but i'm in a different situation. I loved your article, it's inspiring. Thanks for sharing.

Dec 09, 2020

Wow! This was such a good read.

Dec 13, 2020

World are amazing & I love Nature 🙏🏞️🌄🌎🌏🗺️🥰

Dec 17, 2020

Hi there we had a small conversation in Bangkok while Brushing the truth i am so glad to meet you cheers Appreciate it

Dec 22, 2020

And you have written a beautiful blog here 😊

Very inspiring after reading what you have wrote. Yes, the money for buying a ticket is really concerning for me to step out from my comfort zone, and was thiking a lot should I make this work with travel the world with FREE. ❤

Dec 29, 2020

Wer are you from

Jan 04, 2021

Thank you dearly, you have helped me and beyond, I have connections and so do they. Keep sprinkling more kindness, also free lol.

Jan 13, 2021

Thank you so much for all what you've shared am impressed good luck to you bye

Jan 17, 2021

I am very much inspired by your story, I have a account in freelance and upwork. But in freelance they ask me to pay security deposit first is it safe to do so .

Jan 18, 2021

Hi I want to travel world for free

Jan 19, 2021

click bait title and too long text which is a lot of filler text. could be shorter and to the point.

Feb 02, 2021

l am active now in France heading to Spain

Mar 26, 2021

Is this possible with two children?

May 16, 2021

مرحبا انا عندى سؤال هل انا بدفع مصاريف السفر صح ام لا وهل ينفع ان اعمل واخد مال ام لا

May 31, 2021

Such a priceless story that you can even describe with words🙏 I absolutely believe that hapiness can change this World. And when everyone starts to SHARE yourself for others - we will make a planet smile and blossom❤👋

P.s. Thank you for that motivation. I will try to spread around the love which I found here

Jul 23, 2021

Oct 09, 2021

great writing. I hope i can join this life soon enough

Hi Pretty I hope you are doing in good health, I am Asif fresh graduate from United Arab Emirates Dubai. i am interests travel to European countries. i am applying many volunteers position. If you are free then guide me which European countries best cheap for foreigner students. Respectfully thanks for your precious time.

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Fourteenth Amendment , Section 1:

All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.

The doctrine of the “right to travel” actually encompasses three separate rights, of which two have been notable for the uncertainty of their textual support. The first is the right of a citizen to move freely between states, a right venerable for its longevity, but still lacking a clear doctrinal basis. 1 Footnote Saenz v. Roe, 526 U.S. 489 (1999) . “For the purposes of this case, we need not identify the source of [the right to travel] in the text of the Constitution. The right of ‘free ingress and regress to and from’ neighboring states which was expressly mentioned in the text of the Article of Confederation, may simply have been ‘conceived from the beginning to be a necessary concomitant of the stronger Union the Constitution created.’” Id. at 501 (citations omitted). The second, expressly addressed by the first sentence of Article IV, provides a citizen of one state who is temporarily visiting another state the “Privileges and Immunities” of a citizen of the latter state. 2 Footnote Paul v. Virginia, 75 U.S. (8 Wall.) 168 (1869) ( “without some provision . . . removing from citizens of each State the disabilities of alienage in other States, and giving them equality of privilege with citizens of those States, the Republic would have constituted little more than a league of States; it would not have constituted the Union which now exists.” ). The third is the right of a new arrival to a state, who establishes citizenship in that state, to enjoy the same rights and benefits as other state citizens. This right is most often invoked in challenges to durational residency requirements, which require that persons reside in a state for a specified period of time before taking advantage of the benefits of that state’s citizenship.

Durational Residency Requirements

Challenges to durational residency requirements have traditionally been made under the Equal Protection Clause of the Fourteenth Amendment . In 1999, however, the Court approved a doctrinal shift, so that state laws that distinguished between their own citizens, based on how long they had been in the state, would be evaluated instead under the Privileges or Immunities Clause of the Fourteenth Amendment . 3 Footnote Saenz v. Roe, 526 U.S. 489, 502–03 (1999) . The Court did not, however, question the continuing efficacy of the earlier cases.

A durational residency requirement creates two classes of persons: those who have been within the state for the prescribed period and those who have not. 4 Footnote Dunn v. Blumstein, 405 U.S. 330, 334 (1972) . Because the right to travel is implicated by state distinctions between residents and nonresidents, the relevant constitutional provision is the Privileges and Immunities Clause, Article IV, § 2, cl. 1. But persons who have moved recently, at least from state to state, 5 Footnote Intrastate travel is protected to the extent that the classification fails to meet equal protection standards in some respect. Compare Hadnott v. Amos , 320 F. Supp. 107 (M.D. Ala. 1970) (three-judge court), aff’d. per curiam , 405 U.S. 1035 (1972) , with Arlington County Bd. v. Richards, 434 U.S. 5 (1977) . The same principle applies in the commerce clause cases, in which discrimination may run against in-state as well as out-of-state concerns. Cf. Dean Milk Co. v. City of Madison, 340 U.S. 349 (1951) . have exercised a right protected by the Constitution, and the durational residency classification either deters the exercise of that right or penalizes those who have exercised it. 6 Footnote Shapiro v. Thompson, 394 U.S. 618, 629–31, 638 (1969) ; Dunn v. Blumstein, 405 U.S. 330, 338–42 (1972) ; Memorial Hospital v. Maricopa County, 415 U.S. 250 (1974) ; Jones v. Helms, 452 U.S. 412, 420–21 (1981) . See also Oregon v. Mitchell, 400 U.S. 112, 236–39 (1970) (Justices Brennan, White, and Marshall), and id. at 285–92 (Justices Stewart and Blackmun and Chief Justice Burger). Any such classification is invalid “unless shown to be necessary to promote a compelling governmental interest.” 7 Footnote Shapiro v. Thompson, 394 U.S. 618, 634 (1969) (emphasis by Court); Graham v. Richardson, 403 U.S. 365, 375–76 (1971) . The constitutional right to travel has long been recognized, 8 Footnote Crandall v. Nevada, 73 U.S. (6 Wall.) 35 (1868) ; Edwards v. California, 314 U.S. 160 (1941) (both cases in context of direct restrictions on travel). The source of the right to travel and the reasons for reliance on the Equal Protection Clause are questions puzzled over and unresolved by the Court. United States v. Guest, 383 U.S. 745, 758, 759 (1966) , and id. at 763–64 (Justice Harlan concurring and dissenting), id. at 777 n.3 (Justice Brennan concurring and dissenting); Shapiro v. Thompson, 394 U.S. 618, 629–31 (1969) , and id. at 671 (Justice Harlan dissenting); San Antonio School Dist. v. Rodriguez, 411 U.S. 1, 31–32 (1973) ; Jones v. Helms, 452 U.S. 412, 417–19 (1981) ; Zobel v. Williams, 457 U.S. 55, 60 & n.6 (1982) , and id. at 66–68 (Justice Brennan concurring), 78-81 (Justice O’Connor concurring). but it is only relatively recently that the strict standard of equal protection review has been applied to nullify durational residency requirements.

Thus, in Shapiro v. Thompson , 9 Footnote 394 U.S. 618 (1969) . durational residency requirements conditioning eligibility for welfare assistance on one year’s residence in the state 10 Footnote The durational residency provision established by Congress for the District of Columbia was also voided. 394 U.S. at 641–42 . were voided. If the purpose of the requirements was to inhibit migration by needy persons into the state or to bar the entry of those who came from low-paying states to higher-paying ones in order to collect greater benefits, the Court said, the purpose was impermissible. 11 Footnote 394 U.S. at 627–33 . Gaddis v. Wyman , 304 F. Supp. 717 (N.D.N.Y. 1969) , aff’d sub nom. Wyman v. Bowens, 397 U.S. 49 (1970) , struck down a provision construed so as to bar only persons who came into the state solely to obtain welfare assistance. If, on the other hand, the purpose was to serve certain administrative and related governmental objectives—the facilitation of the planning of budgets, the provision of an objective test of residency, minimization of opportunity for fraud, and encouragement of early entry of new residents into the labor force—then the requirements were rationally related to the purpose but they were not compelling enough to justify a classification that infringed a fundamental interest. 12 Footnote 394 U.S. at 633–38 . Shapiro was reaffirmed in Graham v. Richardson, 403 U.S. 365 (1971) (striking down durational residency requirements for aliens applying for welfare assistance), and in Memorial Hospital v. Maricopa County, 415 U.S. 250 (1974) (voiding requirement of one year’s residency in county as condition to indigent’s receiving nonemergency hospitalization or medical care at county’s expense). When Connecticut and New York reinstituted the requirements, pleading a financial emergency as the compelling state interest, they were summarily rebuffed. Rivera v. Dunn , 329 F. Supp. 554 (D. Conn. 1971) , aff’d per curiam , 404 U.S. 1054 (1972) ; Lopez v. Wyman , Civ. No. 1971-308 (W.D.N.Y. 1971) , aff’d per curiam , 404 U.S. 1055 (1972) . The source of the funds, state or federal, is irrelevant to application of the principle. Pease v. Hansen, 404 U.S. 70 (1971) . In Dunn v. Blumstein , 13 Footnote 405 U.S. 330 (1972) . But see Marston v. Lewis, 410 U.S. 679 (1973) , and Burns v. Fortson, 410 U.S. 686 (1973) . Durational residency requirements of five and seven years respectively for candidates for elective office were sustained in Kanapaux v. Ellisor , 419 U.S. 891 (1974) , and Sununu v. Stark , 420 U.S. 958 (1975) . where the durational residency requirements denied the franchise to newcomers, such administrative justifications were found constitutionally insufficient to justify the classification. 14 Footnote For additional discussion of durational residence as a qualification to vote, see Voter Qualifications, supra . The Privileges or Immunities Clause of the Fourteenth Amendment was the basis for striking down a California law that limited welfare benefits for California citizens who had resided in the state for less than a year to the level of benefits that they would have received in the state of their prior residence. 15 Footnote Saenz v. Roe, 526 U.S. 489, 505 (1999) .

However, a state one-year durational residency requirement for the initiation of a divorce proceeding was sustained in Sosna v. Iowa . 16 Footnote 419 U.S. 393 (1975) . Justices Marshall and Brennan dissented on the merits. Id. at 418 . Although it is not clear what the precise basis of the ruling is, it appears that the Court found that the state’s interest in requiring that those who seek a divorce from its courts be genuinely attached to the state and its desire to insulate divorce decrees from the likelihood of collateral attack justified the requirement. 17 Footnote 419 U.S. at 409 . But the Court also indicated that the plaintiff was not absolutely barred from the state courts, but merely required to wait for access (which was true in the prior cases as well and there held immaterial), and that possibly the state interests in marriage and divorce were more exclusive and thus more immune from federal constitutional attack than were the matters at issue in the previous cases. The Court also did not indicate whether it was using strict or traditional scrutiny. Similarly, durational residency requirements for lower in-state tuition at public colleges have been held constitutionally justifiable, again, however, without a clear statement of reason. 18 Footnote Starns v. Malkerson , 326 F. Supp. 234 (D. Minn. 1970) , aff’d per curiam , 401 U.S. 985 (1971) . Cf. Vlandis v. Kline, 412 U.S. 441, 452 & n.9 (1973) , and id. at 456, 464, 467 (dicta). In Memorial Hospital v. Maricopa County, 415 U.S. 250, 256 (1974) , the Court, noting the results, stated that “some waiting periods . . . may not be penalties” and thus would be valid. More recently, the Court has attempted to clarify these cases by distinguishing situations where a state citizen is likely to “consume” benefits within a state’s borders (such as the provision of welfare) from those where citizens of other states are likely to establish residency just long enough to acquire some portable benefit, and then return to their original domicile to enjoy them (such as obtaining a divorce decree or paying the in-state tuition rate for a college education). 19 Footnote Saenz v. Roe , 526 U.S. at 505 .

A state scheme for returning to its residents a portion of the income earned from the vast oil deposits discovered within Alaska foundered upon the formula for allocating the dividends; that is, each adult resident received one unit of return for each year of residency subsequent to 1959, the first year of Alaska’s statehood. The law thus created fixed, permanent distinctions between an ever-increasing number of classes of bona fide residents based on how long they had been in the state. The differences between the durational residency cases previously decided did not alter the bearing of the right to travel principle upon the distribution scheme, but the Court’s decision went off on the absence of any permissible purpose underlying the apportionment classification and it thus failed even the rational basis test. 20 Footnote Zobel v. Williams, 457 U.S. 55 (1982) . Somewhat similar was the Court’s invalidation on equal protection grounds of a veterans preference for state employment limited to persons who were state residents when they entered military service; four Justices also thought the preference penalized the right to travel. Attorney General of New York v. Soto-Lopez, 476 U.S. 898 (1986) .

Still unresolved are issues such as durational residency requirements for occupational licenses and other purposes. 21 Footnote La Tourette v. McMaster, 248 U.S. 465 (1919) , upholding a two-year residence requirement to become an insurance broker, must be considered of questionable validity. Durational periods for admission to the practice of law or medicine or other professions have evoked differing responses by lower courts. But this line of cases does not apply to state residency requirements themselves, as distinguished from durational provisions, 22 Footnote E.g. , McCarthy v. Philadelphia Civil Service Comm’n, 424 U.S. 645 (1976) (ordinance requiring city employees to be and to remain city residents upheld). See Memorial Hospital v. Maricopa County, 415 U.S. 250, 255 (1974) . See also Martinez v. Bynum, 461 U.S. 321 (1983) (bona fide residency requirement for free tuition to public schools). and the cases do not inhibit the states when, having reasons for doing so, they bar travel by certain persons. 23 Footnote Jones v. Helms, 452 U.S. 412 (1981) (statute made it a misdemeanor to abandon a dependent child but a felony to commit the offense and then leave the state).

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10 ways to travel for free in the U.S.

Get creative and see the world without spending a dime

It might seem too good to be true, but there are many legitimate and easy ways you can travel for free in the U.S. With post-pandemic revenge trips on the rise, the costs of travel has risen—up 11 percent from last year!—outpacing the rate of inflation in the U.S., according to NerdWallet's Travel Inflation Report .

Traveling for free can allow you to take the vacation of your dreams even if the economy, travel prices, and your wallet aren't cooperating. For instance, some destinations offer  gratis airfare as a way to attract visitors. Hong Kong Tourism Board's Hello Hong Kong campaign is giving away 500,000 free flights and its HK Goodies is providing one million free welcome gifts. While Taiwan's Tourism Bureau will give 500,000 international tourists NT$5,000 ($165) once they arrive in the country to use toward accommodation, food, and other travel expenses.

Finances, or a lack thereof, don't have to prevent you from packing up and seeing the world this year. From working on farms in exchange for room and board to getting paid to travel while house sitting and pet sitting to embarking on cultural exchanges and contributing your time and talent to an NGO, here are 10 ways to travel for free.

RECOMMENDED: The best cheap family vacations in the U.S.

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How To Travel For Free In The US:

1.  Combine your work with travel

From travel nurse to flight attendant to travel blogging, there are many careers that can provide a long-term work-life balance that includes continuous travel. Travelnursing.org provides skilled nursing placements in all 50 states. The website connects wannabe travel nurses with up to four recruitment agencies that fill short-term work assignments that last between eight and 26 weeks.

Don't have a nursing degree? Au Pair World and InterExchange are platforms that connect host families and au pairs from around the world.

Travelers can sail the seven seas while working in hospitality, entertainment, retail, spa, photography and more aboard a cruise ship. Job board All Cruise Jobs and individual cruise line career websites list paid jobs in all areas of the cruise industry while CrewSeekers , Yacrew , and Find a Crew list opportunities for amateur and professional yacht and superyacht crews.

2.  Take a working holiday

Have commitment issues? Whether you want to work for a few days, a week, or longer, working holidays offer the chance to work short-term or seasonally in exchange for free room and board and, oftentimes, airfare too. Season Workers lists temporary and seasonal work at ski resorts and summer camps while Yoga Trade facilitates yoga-based exchanges globally by connecting yoga instructors to jobs, and Adventure Work posts adventure and ski resort jobs.

Looking to work with an NGO, contribute to a sustainable project, or experience a cultural exchange? Workaway is a platform for arranging homestays and cultural exchanges. Workawayers work for about five hours per day in exchange for accommodation and food.

Some of the most popular working holidays are teaching English abroad in programs like the Japan Exchange and Teaching Program . Founded in 1987, the government-run JET Program has placed more than 70,000 participants in schools and government offices throughout Japan. Participants' salary begins at $25,500 annually and airfare, visa, insurance, and orientation are provided (housing help is given but participants pay full costs). TEFL and Dave's ESL Cafe are job listings websites specifically for English teaching jobs abroad.

Several countries like Australia , Ireland , New Zealand , and Singapore offer working holiday visas to Americans, which allow young adults the ability to work legally while also having the chance to travel and explore the country.

3.  Become a sitter

While you will have to pay for your travel to and from these destinations, house sitting and pet sitting let you live like a local for free while watering the plants, picking up the mail, and cuddling with furry friends. Online communities, including HouseCarers and MindMyHouse , connect homeowners with housesitters while Animal Aunts and TrustedHousesitters match house sitters and pet sitters who want to care for cats, dogs, horses, birds, fish, and reptiles.

4.  Swap houses or couch surf—or both!

Looking for something more low-key? Live like a local for free with Couchsurfing , an online community of 12 million people in 200,000 cities who have been sharing their couches and love for their locales since 2004, and the newer, nonprofit Couchers . Want a place all to yourself? Consider a house swap, where you trade your place for someone else's. HomeExchange has members in more than 130 countries, HomeLink has been running its worldwide home-swapping network since 1953, and Love Home Swap offers classic or points-based swaps in 100-plus countries.

5.  Offer to move someone's car

Turn miles into money and a free road trip by transporting automobiles of all makes, models, and sizes across the U.S. Driving for a vehicle relocation company like Auto Driveaway or Transfercar is an easy way to help companies move their vehicles cross country. For Auto Driveaway, applicants must be 23 to 75 years old and have a driver's license and a clean driving record. For Transfercar, drivers help rental car companies relocate their cars and RVs and must be 18 years old (21 years old in some states) and have a driver's license that is valid in the U.S. and Canada.

6.  Plan around a work trip

Business travel + leisure = bleisure. If you have a job that requires you to hit the road from time to time, incorporate your next vacation into your work trip. When booking trips for work, try to fly out a day before or after to squeeze in some vacay time. On a tight schedule? Resist the temptation to stay in after a long day of work. Go out to eat, take a stroll, and visit attractions like museums that are open into the evening. Also, book an early morning flight to your destination so you can squeeze in a half day of sightseeing and book an afternoon or evening flight on your last day for last-minute shopping or touring. If you don't already have a job that includes business travel, consider switching to a career in sales, hospitality, and event planning, which often require some travel.

7.  Cash in those points!

There are many ways to convert everyday spending into free travel. Get credit cards like the Delta SkyMiles American Express card, which comes with annual benefits like a free companion ticket, Delta Sky Club access, and fee credit for Global Entry or TSA PreCheck, and the Chase Sapphire card, which provides an annual travel credit, points on Lyft, and generous points for travel and dining purchases. The points earned on these credit cards can be converted to plane tickets and hotel stays. Joining hotel loyalty programs is another way to rack up free nights.

8.  Volunteer with an organization

Lending your time and talent to teach, work on a farm, or do other work in exchange for room and board and, sometimes, airfare is an easy way to see the world. There are several volunteer programs.

For more than 60 years, the Peace Corps has partnered with 60 host countries on hands-on, grassroots-driven projects like education and health campaigns. Founded in 1993 by President Bill Clinton, the government-run AmeriCorps arranges a variety of service projects, ranging from three months to one year across the U.S. AmeriCorps members receive transportation to their assigned campus and projects, accommodations, and a living allowance of $180 to $500 every two weeks.

Looking for shorter volunteer travel? The Worldwide Opportunities on Organic Farms ( WWOOF ) pairs WWOOFers with organic farm hosts in 130 countries. Active vacationers work on the farm for about 25 hours per week and, in exchange, get room and board in a rural setting, learn about farming and gardening, and engage in a cultural exchange. HelpX is similar to farm stays and ranches plus hostels and sailing boats that seek helpers in exchange for accommodation and food.

HelpStay lists 1,500 volunteer stays in 100 countries while Worldpackers and Go Overseas lists thousands of volunteer opportunities worldwide. Pueblo Inglés offers transportation from Barcelona, Madrid, or Munich, accommodations in a shared room, and meals in exchange for participants to speak English for up to 12 hours per day for one week with locals in Germany and Spain.

9.  Go on a heritage trip

Depending on your heritage, you may be able to take a free or heavily subsidized government or nonprofit-run "birthright" trip. Subsidized programs where participants pay a modest fee include Birthright Armenia , a homestay and volunteerism program from nine weeks to one year that includes accommodation and some travel reimbursement, the 14-day Domovina Birthright Program to Croatia for adults of Croatian descent 18 to 30 years old, Birthright Macedonia , which offers a three-week homestay and internship program, ReConnect Hungary , which offers several birthright and volunteer programs, and Taiwan Study Tour , also known as the "Love Boat" for the many romances that come from it, which is a three-week summer study tour for overseas Chinese.

Birthright programs that offer free trips include Birthright AFRICA , which offers a 10-day trip to Africa to U.S. citizens 13 to 30 years old of Black/African descent, and Birthright Israel , which offers a 10-day trip to Israel to eligible Jewish adults 18 to 26 years old.

10.  Get yourself bumped from a flight

If the crew on your next flight asks for volunteers willing to get "bumped" and give up their seats, you might want to take them up on the offer. When there are more passengers for a flight than there are seats, some passengers need to get "bumped" or denied boarding. Before getting involuntarily bumped, the airline must ask if there are any passengers willing to give up their seats in exchange for compensation like money or vouchers, according to the U.S. Department of Transportation .

Getting bumped from a flight is often an easy way to immediately rack up extra cash for your vacation in exchange for taking a later flight. Be sure to ask when the next flight is, if your ticket for that flight is on standby or confirmed, and if the airline will provide other compensation like meals and hotel. If the airline is also offering you a voucher for future travel, learn what restrictions there might be before you agree to get bumped.

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The Right to Travel

The doctrine of the "right to travel" actually encompasses three separate rights, of which two have been notable for the uncertainty of their textual support. The first is the right of a citizen to move freely between states, a right venerable for its longevity, but still lacking a clear doctrinal basis. 1858 The second, expressly addressed by the first sentence of Article IV, provides a citizen of one State who is temporarily visiting another state the "Privileges and Immunities" of a citizen of the latter state. 1859 The third is the right of a new arrival to a state, who establishes citizenship in that state, to enjoy the same rights and benefits as other state citizens. This right is most often invoked in challenges to durational residency requirements, which require that persons reside in a state for a specified period of time before taking advantage of the benefits of that state's citizenship.

1858 Saenz v. Roe, 526 U.S. 489 (1999). "For the purposes of this case, we need not identify the source of [the right to travel] in the text of the Constitution. The right of free ingress and regress to and from' neighboring states which was expressly mentioned in the text of the Article of Confederation, may simply have been conceived from the beginning to be a necessary concomitant of the stronger Union the Constitution created."' Id. at 501 (citations omitted).

1859 Paul v. Virginia, 75 U.S. (8 Wall.) 168, 180 (1868) ("without some provision . . . removing from citizens of each State the disabilities of alienage in other States, and giving them equality of privilege with citizens of those States, the Republic would have constituted little more than a league of States; it would not have constituted the Union which now exists.").

Durational Residency Requirements .—Challenges to durational residency requirements have traditionally been made under the Equal Protection Clause of the Fourteenth Amendment. In 1999, however, a majority of the Supreme Court approved a doctrinal shift, so that state laws which distinguished between their own citizens based on how long they had been in the state would be evaluated instead under the Privileges or Immunities Clause of the Fourteenth Amendment. 1860 The Court did not, however, question the continuing efficacy of the earlier cases.

A durational residency requirement creates two classes of persons: those who have been within the State for the prescribed period and those who have not been. 1861 But persons who have moved recently, at least from State to State, 1862 have exercised a right protected by the Constitution of the United States, and the durational residency classification either deters the exercise of the right or penalizes those who have exercised the right. 1863 Any such classification is invalid "unless shown to be necessary to promote a compelling governmental interest ." 1864 The constitutional right to travel has long been recognized, 1865 but it is only relatively recently that the strict standard of equal protection review has been applied to nullify those durational residency provisions which have been brought before the Court.

1860 Saenz v. Roe, 526 U.S. 489, 502-03 (1999).

1861 Dunn v. Blumstein, 405 U.S. 330, 334 (1972). Inasmuch as the right to travel is implicated by state distinctions between residents and nonresidents, the relevant constitutional provision is the privileges and immunities clause, Article IV, § 2, cl. 1.

1862 Intrastate travel is protected to the extent that the classification fails to meet equal protection standards in some respect. Compare Hadnott v. Amos, 320 F. Supp. 107 (M.D. Ala. 1970) (three-judge court), aff'd. per curiam , 405 U.S. 1035 (1972), with Arlington County Bd. v. Richards, 434 U.S. 5 (1977). The same principle applies in the commerce clause cases, in which discrimination may run against in-state as well as out-of-state concerns. Cf. Dean Milk Co. v. City of Madison, 340 U.S. 349 (1951).

1863 Shapiro v. Thompson, 394 U.S. 618, 629-31, 638 (1969); Dunn v. Blumstein, 405 U.S. 330, 338-42 (1972); Memorial Hospital v. Maricopa County, 415 U.S. 250 (1974); Jones v. Helms, 452 U.S. 412, 420-21 (1981). See also Oregon v. Mitchell, 400 U.S. 112, 236-39 (1970) (Justices Brennan, White, and Marshall), and id. at 285-92 (Justices Stewart and Blackmun and Chief Justice Burger).

1864 Shapiro v. Thompson, 394 U.S. 618, 634 (1969) (emphasis by Court); Graham v. Richardson, 403 U.S. 365, 375-76 (1971).

1865 Crandall v. Nevada, 73 U.S. (6 Wall.) 35 (1868); Edwards v. California, 314 U.S. 160 (1941) (both cases in context of direct restrictions on travel). The source of the right to travel and the reasons for reliance on the equal protection clause are questions puzzled over and unresolved by the Court. United States v. Guest, 383 U.S. 745, 758, 759 (1966), and id. at 763-64 (Justice Harlan concurring and dissenting), id. at 777 n.3 (Justice Brennan concurring and dissenting); Shapiro v. Thompson, 394 U.S. 618, 629-31 (1969), and id. at 671 (Justice Harlan dissenting); San Antonio School Dist. v. Rodriguez, 411 U.S. 1, 31-32 (1973); Jones v. Helms, 452 U.S. 412, 417-19 (1981); Zobel v. Williams, 457 U.S. 55, 60 & n.6 (1982), and id. at 66-68 (Justice Brennan concurring), 78-81 (Justice O'Connor concurring).

Thus, in Shapiro v. Thompson , 1866 durational residency requirements conditioning eligibility for welfare assistance on one year's residence in the State 1867 were voided. If the purpose of the requirements was to inhibit migration by needy persons into the State or to bar the entry of those who came from low-paying States to higher-paying ones in order to collect greater benefits, the Court said, the purpose was impermissible. 1868 If on the other hand the purpose was to serve certain administrative and related governmental objectives—the facilitation of the planning of budgets, the provision of an objective test of residency, minimization of opportunity for fraud, and encouragement of early entry of new residents into the labor force—the requirements were rationally related to the purpose but they were not compelling enough to justify a classification which infringed on a fundamental interest. 1869 Similarly, in Dunn v. Blumstein , 1870 where the durational residency requirements denied the franchise to newcomers, the assertion of such administrative justifications was constitutionally insufficient to justify the classification. The Privileges or Immunities Clause of the Fourteenth Amendment was the basis for striking down a California law which limited welfare benefits for California citizens who had resided in the state for less than a year to the level ifof benefits which they would have received in the State of their prior residence. 1871

1866 394 U.S. 618 (1969).

1867 The durational residency provision established by Congress for the District of Columbia was also voided. 394 U.S. at 641-42.

1868 394 U.S. at 627-33. Gaddis v. Wyman, 304 F. Supp. 717 (N.D.N.Y. 1969), aff'd sub nom. Wyman v. Bowens, 397 U.S. 49 (1970), struck down a provision construed so as to bar only persons who came into the State solely to obtain welfare assistance.

1869 394 U.S. at 633-38. Shapiro was reaffirmed in Graham v. Richardson, 403 U.S. 365 (1971) (striking down durational residency requirements for aliens applying for welfare assistance), and in Memorial Hospital v. Maricopa County, 415 U.S. 250 (1974) (voiding requirement of one year's residency in county as condition to indigent's receiving nonemergency hospitalization or medical care at county's expense). When Connecticut and New York reinstituted the requirements, pleading a financial emergency as the compelling state interest, they were summarily rebuffed. Rivera v. Dunn, 329 F. Supp. 554 (D. Conn. 1971), aff'd per curiam , 404 U.S. 1054 (1972); Lopez v. Wyman, Civ. No. 1971-308 (W.D.N.Y. 1971), aff'd per curiam , 404 U.S. 1055 (1972). The source of the funds, state or federal, is irrelevant to application of the principle. Pease v. Hansen, 404 U.S. 70 (1971).

1870 405 U.S. 330 (1972). But see Marston v. Lewis, 410 U.S. 679 (1973), and Burns v. Fortson, 410 U.S. 686 (1973). Durational residency requirements of five and seven years respectively for candidates for elective office were sustained in Kanapaux v. Ellisor, 419 U.S. 891 (1974), and Sununu v. Stark, 420 U.S. 958 (1975).

1871 Saenz v. Roe, 526 U.S. 489, 505 (1999).

However, a state one-year durational residency requirement for the initiation of a divorce proceeding was sustained in Sosna v. Iowa . 1872 While it is not clear what the precise basis of the ruling is, it appears that the Court found that the State's interest in requiring that those who seek a divorce from its courts be genuinely attached to the State and its desire to insulate divorce decrees from the likelihood of collateral attack justified the requirement. 1873 Similarly, durational residency requirements for lower in-state tuition at public colleges have been held constitutionally justifiable, again, however, without a clear statement of reason. 1874 More recently, the Court has attempted to clarify these cases by distinguishing situations where a state citizen is likely to "consume" benefits within a state's borders (such as the provision of welfare) from those where citizens of other states are likely to establish residency just long enough to acquire some portable benefit, and then return to their original domicile to enjoy them (such as obtaining a divorce decree or paying the in-state tuition rate for a college education). 1875

A state scheme for returning to its residents a portion of the income earned from the vast oil deposits discovered within Alaska foundered upon the formula for allocating the dividends; that is, each adult resident received one unit of return for each year of residency subsequent to 1959, the first year of Alaska's statehood. The law thus created fixed, permanent distinctions between an ever-increasing number of classes of bona fide residents based on how long they had been in the State. The differences between the durational residency cases previously decided did not alter the bearing of the right to travel principle upon the distribution scheme, but the Court's decision went off on the absence of any permissible purpose underlying the apportionment classification and it thus failed even the rational basis test. 1876

1872 419 U.S. 393 (1975). Justices Marshall and Brennan dissented on the merits. Id. at 418.

1873 419 U.S. at 409. But the Court also indicated that the plaintiff was not absolutely barred from the state courts, but merely required to wait for access (which was true in the prior cases as well and there held immaterial), and that possibly the state interests in marriage and divorce were more exclusive and thus more immune from federal constitutional attack than were the matters at issue in the previous cases. The Court also did not indicate whether it was using strict or traditional scrutiny.

1874 Starns v. Malkerson, 326 F. Supp. 234 (D.Minn. 1970), aff'd per curiam , 401 U.S. 985 (1971). Cf. Vlandis v. Kline, 412 U.S. 441, 452 & n.9 (1973), and id. at 456, 464, 467 (dicta). In Memorial Hospital v. Maricopa County, 415 U.S. 250, 256 (1974), the Court, noting the results, stated that "some waiting periods . . . may not be penalties" and thus would be valid.

1875 Saenz v. Roe, 526 U.S. at 505 (1999).

1876 Zobel v. Williams, 457 U.S. 55 (1982). Somewhat similar was the Court's invalidation on equal protection grounds of a veterans preference for state employment limited to persons who were state residents when they entered military service; four Justices also thought the preference penalized the right to travel. Attorney General of New York v. Soto-Lopez, 476 U.S. 898 (1986).

Unresolved still are issues such as durational residency requirements for occupational licenses and other purposes. 1877 Too, it should be noted that this line of cases does not apply to state residency requirements themselves, as distinguished from durational provisions, 1878 and the cases do not inhibit the States when, having reasons for doing so, they bar travel by certain persons. 1879

1877 La Tourette v. McMaster, 248 U.S. 465 (1919), upholding a two-year residence requirement to become an insurance broker, must be considered of questionable validity. Durational periods for admission to the practice of law or medicine or other professions have evoked differing responses by lower courts.

1878 E.g. , McCarthy v. Philadelphia Civil Service Comm'n, 424 U.S. 645 (1976) (ordinance requiring city employees to be and to remain city residents upheld). See Memorial Hospital v. Maricopa County, 415 U.S. 250, 255 (1974). See also Martinez v. Bynum, 461 U.S. 321 (1983) (bona fide residency requirement for free tuition to public schools).

1879 Jones v. Helms, 452 U.S. 412 (1981) (statute made it a misdemeanor to abandon a dependent child but a felony to commit the offense and then leave the State).

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How to Get Free Flights (Or Close to It)

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You may have seen or heard it. At the workplace water cooler, the holiday dinner table and just about every place else you go, proud travel hackers are boasting about scoring free flights to far-off destinations.

Ready to get in on the action? Here’s everything you need to know about how to get free flights, starting with a caveat: "Free flights” aren’t usually free. You often pay at least $5.60 each way for Transportation Security Administration fees on your ticket. For certain international flights, you'll also be on the hook for fuel surcharges , which can sometimes cost around $200 each way for economy class and more than $700 each way in business class.

Now that you know award travel means “mostly” free, here are the most reliable ways to get free flights.

5 ways to get free flights

With time, strategic spending and the right credit cards, you'll be well on your way to flying at deep discounts.

1. Earn miles or points by flying your preferred airline

Sign up for an airline loyalty program (joining is free). Every time you fly the airline, you will earn miles or points that can be redeemed for free flights.

» Learn more: How do airline miles work?

The number of miles you earn varies by airline. Most award you miles based on the cash price of your ticket. For example, United Airlines’ MileagePlus program members earn 5 MileagePlus miles per dollar spent on qualifying tickets. Premier members of the program get bonus miles on top of that.

Other airlines, such as Hawaiian Airlines, award miles based on how far you fly. A 2,397-mile flight from San Francisco to Honolulu, for example, puts 2,397 HawaiianMiles in your loyalty program account.

You can also earn miles with your preferred airline by flying on one of its partners . For example, if you fly JetBlue, you can use your HawaiianMiles member number when booking to earn miles on Hawaiian. Or, book a flight to Paris on Air France , use your Delta Air Lines SkyMiles number when booking and you’ll earn Delta miles for your trip. Determine which airlines partner with your preferred carrier to see all your options for earning miles.

» Learn more: Plan your next redemption with our airline points tool

So how many miles do you need to rack up before you have enough for a free flight? That depends on the airline miles you collect, where you’re going and when. Search your preferred airline’s website for sample award bookings for your travel dates and other dates to see how award prices can vary.

To give you an idea of how far your miles can take you, NerdWallet keeps a regularly updated chart showing the estimated cash value of each mile or point from some major airline loyalty programs.

2. Earn miles making everyday purchases with an airline credit card

Airlines partner with financial institutions to offer airline credit cards that award your spending with miles or points deposited directly into your loyalty program account. You can earn enough points or miles for an award flight without ever buying a plane ticket with one of these credit cards.

If you want to avoid paying out-of-pocket for a credit card, several no annual fee travel cards are worth considering.

The trick is to choose an airline card that offers the most points and miles for your spending style.

For example:

If you spend a lot on groceries and you usually fly American Airlines, choose a card like the American Airlines AAdvantage® MileUp® , which pays 2x miles for every dollar you spend at U.S. supermarkets.

Prefer dining out? Lots of cards will up your rewards when you make charges at restaurants. If you’re a more frequent United flyer, the United℠ Explorer Card also offers 2 United miles per dollar on dining purchases, including eligible delivery services.

With the Delta SkyMiles® Gold American Express Card , you can earn bonus miles for both cooking at home and eating out. You’ll earn 2 SkyMiles per dollar on restaurant purchases and at U.S. supermarkets. Terms apply.

Before you sign up for a card, think about where you spend most of your money. Then compare credit card annual fees, and find one that fits your budget and has valuable benefits.

» Learn more: The best airline credit cards right now

3. Earn thousands of miles as a credit card welcome bonus

The fastest way to get enough miles for a free flight is to snag a credit card “ welcome bonus .” These offers typically include a big stack of points or miles, often in the tens of thousands. You earn this welcome bonus when you sign up as a new cardmember then hit a spending minimum in a set period — usually the first three months after opening.

For example, the Alaska Airlines Visa Signature® credit card is offering this welcome bonus: Get 60,000 bonus miles plus Alaska's Famous Companion Fare™ ($99 fare plus taxes and fees from $23) with this offer. To qualify, make $3,000 or more in purchases within the first 90 days of opening your account.

4. Earn flexible points using a non-airline credit card

Chase, American Express, Capital One, Citi and other financial institutions offer travel credit cards that pay points. You can redeem points for flights on the issuer’s travel booking site or, for some of these programs, convert your points into your favorite airline's miles. Others allow you to redeem them for a statement credit to compensate for the cost of a flight or hotel.

For example, the Bank of America® Travel Rewards credit card earns you 1.5 points per dollar. You can use those points to book a free flight in Bank of America’s travel booking portal, or you can purchase a flight using the credit card, then apply your points for a statement credit to offset the purchase.

These flexible rewards cards give you a more comprehensive selection of airlines to choose from. But they don’t offer some perks, like free checked bags or bonus miles for buying same-brand flights with an airline's co-branded card.

Airline-branded cards work best for travelers who favor a single airline, while broader travel rewards cards are better for those who aren’t loyal to one brand.

5. Earn an airline companion pass

Some airlines offer a chance to earn a “companion pass,” which lets a second passenger fly with you for free (not including taxes or fees). For example, you can earn the Southwest Companion Pass by flying 100 one-way flights or accumulating 135,000 qualifying points through purchasing flights or spending on a Southwest credit card . The Southwest Companion Pass lets you pick one person who can fly with you on the same itinerary for the cost of taxes and fees, which start at $5.60 each way. It’s valid for the remainder of the year in which you earned it, plus the entire following calendar year. You can even change your designated companion up to three times a year.

The Alaska Airlines Visa Signature® credit card also comes with a one-time-use companion fare each year, which gets your companion on a flight with you starting at just $122 (($99 fare plus taxes and fees from $23).

If you want to fly for free ...

Travelers who want to join the ranks of those who get free plane tickets, plan your strategy carefully. First, consider where you’ll travel and on what airlines. Next, sign up for loyalty programs, then look at credit card welcome bonuses and other ways to earn miles. Even if you don’t make a lot of credit card charges, you can slowly work toward low-cost or nearly free airline tickets.

How to maximize your rewards

You want a travel credit card that prioritizes what’s important to you. Here are our picks for the best travel credit cards of 2024 , including those best for:

Flexibility, point transfers and a large bonus: Chase Sapphire Preferred® Card

No annual fee: Bank of America® Travel Rewards credit card

Flat-rate travel rewards: Capital One Venture Rewards Credit Card

Bonus travel rewards and high-end perks: Chase Sapphire Reserve®

Luxury perks: The Platinum Card® from American Express

Business travelers: Ink Business Preferred® Credit Card

on Chase's website

1x-5x 5x on travel purchased through Chase Travel℠, 3x on dining, select streaming services and online groceries, 2x on all other travel purchases, 1x on all other purchases.

60,000 Earn 60,000 bonus points after you spend $4,000 on purchases in the first 3 months from account opening. That's $750 when you redeem through Chase Travel℠.

1.5%-6.5% Enjoy 6.5% cash back on travel purchased through Chase Travel; 4.5% cash back on drugstore purchases and dining at restaurants, including takeout and eligible delivery service, and 3% on all other purchases (on up to $20,000 spent in the first year). After your first year or $20,000 spent, enjoy 5% cash back on travel purchased through Chase Travel, 3% cash back on drugstore purchases and dining at restaurants, including takeout and eligible delivery service, and unlimited 1.5% cash back on all other purchases.

$300 Earn an additional 1.5% cash back on everything you buy (on up to $20,000 spent in the first year) - worth up to $300 cash back!

on Capital One's website

2x-5x Earn unlimited 2X miles on every purchase, every day. Earn 5X miles on hotels and rental cars booked through Capital One Travel, where you'll get Capital One's best prices on thousands of trip options.

75,000 Enjoy a one-time bonus of 75,000 miles once you spend $4,000 on purchases within 3 months from account opening, equal to $750 in travel.

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Tech-free Trips Are on the Rise — From Hotels With No Wi-Fi to Multiday Retreats With No Phones Allowed

If breaking-news overload and digital distractions are taking their toll on your mental health, the time may be right for a phone-free vacation. One writer has dialed up the details.

Adam Firman/Courtesy of Unplugged

Would "Eat, Pray, Love" author Elizabeth Gilbert have fallen so deeply in love with Neapolitan pizza if she’d been taking photos of her pie to post on Instagram? What if Steinbeck had traveled with Charley and Waze? These days, iPhones, laptops, and tablets — not to mention fitness trackers and smart watches — are ubiquitous, making it feel all but impossible to truly disconnect. 

“There used to be a distinction between home and away,” says Trine Syvertsen, whose 2020 book "Digital Detox: The Politics of Disconnecting," examines the dissolution of that boundary. These days, Syvertsen adds, “people do all sorts of things to self-restrict their media use,” including turning off notifications or switching on airplane mode while on the ground. Proof of the interest in going phone-free can be found on Reddit, where forums like r/nosurf and r/PhonesAreBad host discussions on how to more effectively log off while on vacation.

Now, travelers can choose from a growing number of intentionally tech-free trips. Consider the start-up Italian travel agency Logout Livenow , which organizes one- to five-day retreats in Sardinia on which guests lock away their phones in order to hike, kayak, practice yoga — and reconnect with themselves.

Cofounder Gavino Puggioni says that arrivals are visibly anxious when they hand over their devices and will often continue to reflexively touch their empty back pockets. But they eventually forget about their phones and start chatting with each other, says one recent participant, Mauro Luzzu. “Instead of three days, it felt like we had seven,” recalls the Graz, Austria–based software engineer. “Time really expanded.” 

Tara Cappel, founder of the agency FTLO Travel , has noticed something similar. After successfully instituting a no-phones-at-dinner rule on some of her company’s group itineraries, she’s launched a series of “phone-free trips” to destinations such as Costa Rica, Cuba, Iceland, and Portugal. (Digital cameras are still allowed.)

“Without that distraction, the experience feels so much richer because you’re just immersed in it,” Cappel says.

Hospitality brands are also embracing the trend. Eremito , in the hills of Umbria, Italy, has no Wi-Fi — but does offer a heated plunge pool, yoga classes, and candlelit vegetarian meals. Luxury spas including Rancho La Puerta , in Baja California, and Miraval Resorts , which has three resorts in the U.S., discourage phones and laptops in common areas.

Courtesy of FTLO Travel

In the U.K., Unplugged now has a network of 19 tech-free cabins within an hour or two of London or Manchester. They’ve proven particularly popular with couples, says cofounder Hector Hughes. “People who have been in a relationship for ten years haven’t spent a day together without phones,” he observes. In the U.S., the company Getaway offers a similar approach, with hundreds of tiny-home hideaways within a short drive of major metro areas. 

Courtesy of Miraval Berkshires 

Many experts emphasize the need to avoid half measures. “The most effective retreats happen when you’re completely disconnected,” says Melissa Huey, a behavioral scientist. It’s a lesson I learned the hard way recently on a two-week writing retreat in the woods of Georgia. With Wi-Fi limited to only one spot on campus, I found myself obsessing over when I’d be able to check my messages, rather than enjoying the opportunity to log off. “It’s an addiction,” Huey acknowledges.

For London-based photographer Elena Bazu, a weekend alone in an Unplugged cabin was much more successful. “For the first day, it was scary,” she admits, “but on the second day I was okay.” Since then, she has committed to weekly walks without her phone. “I feel much better, mentally and physically, when I’m not checking it all the time.”

A version of this story first appeared in the March 2024 issue of  Travel + Leisure  under the headline “The Lo-fi Cure for 2024.”

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