delivered the opinion of the Court.

We noted probable jurisdiction to decide whether a New Mexico statute that grants a tax exemption limited to those Vietnam veterans who resided in the State before May 8, 1976, violates the Equal Protection Clause of the Fourteenth Amendment.

I

Pursuant to Art. VIII, § 5, of the New Mexico Constitution, the New Mexico State Legislature has granted annual property tax exemptions to residents who served in the Armed Forces. As applied to Vietnam veterans currently residing in New Mexico, § 7-37-5 of the New Mexico Statutes1 exempts $2,000 of the taxable value of property for any honorably discharged Vietnam veteran who served on active duty during the Vietnam War for at least 90 continuous days, N. M. Stat. Ann. §§7-37-5(0(1) and (2) (1983), and who was a New Mexico resident before May 8, 1976, § 7-37-5(C)(3)(d).2

*615Appellants, Alvin D. Hooper and his wife Mary, established residence in New Mexico on August 17, 1981. During the Vietnam War, Alvin Hooper had served for over 90 continuous days as a member of the United States Army; Hooper was honorably discharged in September 1965. For the 1983 tax year, the Hoopers applied for the $2,000 veterans’ tax exemption with respect to their jointly held real property in Bernalillo County. Appellee, the Bernalillo County Assessor, denied the claim because Hooper had not been a state resident before May 8, 1975.

Appellants challenged § 7-37-5(C)(3)(d) as violative of their right to equal protection of the law and their constitutional right to migrate to New Mexico. After a hearing, the Ber-nalillo County Valuation Board rejected appellants’ constitutional challenge and upheld the Assessor’s denial of the tax exemption.3

The New Mexico Court of Appeals affirmed. 101 N. M. 172, 679 P. 2d 840, cert. denied, 101 N. M. 77, 678 P. 2d 705 (1984). The court, noting that the statute did not affect “such fundamental interests as voting, welfare benefits, or public medical assistance,” concluded that the statute did not unconstitutionally burden an exercise of the right to travel. Id., at 175, 679 P. 2d, at 843. The court held that the statute *616was consistent with the Equal Protection Clause because it “reflects legitimate state purposes” and “bears a reasonable relationship to those purposes.” Ibid. The court reasoned that “[a] state’s interest in expressing gratitude and rewarding its pwn citizens for honorable military service is a rational basis for veterans’ preferences,” and that the state legislature is “entitled to limit the period of time within which [veterans] may choose to establish residency.” Id., at 176, 679 P. 2d at 844.

We noted probable jurisdiction. 469 U. S. 878 (1984). We reverse.

II

The New Mexico veterans’ tax exemption differs from the durational residence requirements the Court examined in Sosna v. Iowa, 419 U. S. 393 (1975); Memorial Hospital v. Maricopa County, 415 U. S. 250 (1974); Dunn v. Blumstein, 405 U. S. 330 (1972); and Shapiro v. Thompson, 394 U. S. 618 (1969). The statutes at issue in those cases conditioned eligibility for certain benefits, otherwise available on an equal basis to all residents, on a new resident’s living in the State for a fixed minimum period.4 The durational ^residence requirements purported to assure that only persons who had established bona fide residence received the benefits provided residents of the States.

The New Mexico statute does not impose any threshold waiting period on those resident veterans seeking the tax exemption; resident veterans are entitled to the exemption provided they satisfy the statute’s other criteria. Nor does the statute purport to establish a test of the bona fides of state residence. Instead, the tax exemption contains a fixed-date residence requirement. The statute thus divides *617resident Vietnam veterans into two groups: resident veterans who resided in the State before May 8, 1976, qualify for the exemption;5 resident veterans who established residence after that date do not. Like the Alaska dividend distribution law examined in Zobel v. Williams, 457 U. S. 55 (1982), the tax exemption statute thus creates “fixed, permanent distinctions between . . . classes of concededly bona fide residents” based on when they arrived in the State. Id., at 59.

Appellants established residence in New Mexico several months after the 1981 amendment set the eligibility date as May 8, 1975. Appellants have no quarrel with the legislature’s changing the eligibility date after veterans have chosen to reside in New Mexico, for the enactment date is irrelevant to qualification for the tax exemption. Appellants instead challenge the distinction made by the State within the class of Vietnam veterans who currently are bona fide residents. Their challenge is that the exemption is accorded to those resident Vietnam veterans who resided in the State sometime before May 8, 1976, but not to those Vietnam veterans who have arrived since then.

*618When a state distributes benefits unequally, the distinctions it makes are subject to scrutiny under the Equal Protection Clause of the Fourteenth Amendment.6 Generally, a law will survive that scrutiny if the distinction rationally furthers a legitimate state purpose. Appellants claim that the distinction made by the New Mexico statute should be subjected to the higher level of scrutiny applied to the durational residence requirements in Memorial Hospital v. Maricopa County, supra, and Shapiro v. Thompson, supra. Alternatively, appellants claim that the statute cannot withstand the minimum rationality inquiry applied to the Alaska dividend distribution law in Zobel v. Williams, supra. Ap-pellee, on the other hand, asserts that the statute need only satisfy the latter standard of review. As in Zobel, if the statutory scheme cannot pass even the minimum rationality test, our inquiry ends.

Ill

The New Mexico Court of Appeals accepted two justifications for the distinction made by the Vietnam veterans’ tax exemption statute: the exemption encourages veterans to settle in the State and it serves as an expression of the *619State’s appreciation to its “own citizens for honorable military service.” 101 N. M., at 176, 679 P. 2d, at 844. Before this Court, the latter purpose has been refined as assisting “veterans who, as [New Mexico] citizens, were dependent on [the State] during a time of upheaval in their lives.” Brief for Appellee 22. This rationale assumes that the State accepted a special responsibility toward those veterans who “picked up or laid down the burdens of war” as state residents.7

A

The distinction New Mexico makes between veterans who established residence before May 8, 1976, and those veterans who arrived in the State thereafter bears no rational relationship to one of the State’s objectives — encouraging Vietnam veterans to move to New Mexico. The legislature set this eligibility date long after the triggering event occurred. See n. 2, supra. The legislature cannot plausibly encourage veterans to move to the State by passing such retroactive legislation.8 It is possible that some Vietnam veterans, at least since 1981, might have been discouraged from settling in New Mexico given the State’s exclusion of new resident veterans from a benefit available only to those veterans who resided in the State before May 8, 1976. “The separation of residents into classes hardly seems a likely way to persuade *620new [residents] that the State welcomes them and wants them to stay.” Zobel v. Williams, 457 U. S., at 62, n. 9.9

B

The second purpose of the statute — rewarding veterans who resided in the State before May 8, 1976, for their military service — was primarily relied upon by the New Mexico Court of Appeals to support the statute’s distinction between resident veterans. One component of this rationale is, of course, plainly legitimate; only recently we observed that “[o]ur country has a longstanding policy of compensating veterans for their past contributions by providing them with numerous advantages.” Regan v. Taxation With Representation of Wash., 461 U. S. 540, 551 (1983) (footnote omitted); see Personnel Administrator of Mass. v. Feeney, 442 U. S. 256, 279, n. 25 (1979). And as Judge Friendly has noted, the various preferences for veterans are grounded in a “[djesire to compensate in some measure for the disruption of a way of life . . . and to express gratitude . . . .” Russell v. Hodges, 470 F. 2d 212, 218 (CA2 1972). See Regan v. Taxation With Representation of Wash., supra, at 551.

Consistent with this policy, the State may award certain benefits to all its bona fide veterans, because it then is making neither an invidious nor irrational distinction among its residents. Resident veterans, as a group, may well deserve preferential treatment,10 and such differential treatment visa-vis non-veterans does not offend the Equal Protection Clause. See, e. g., Personnel Administrator of Mass. v. Feeney, supra; see also Johnson v. Robison, 415 U. S. 361 (1974).

*621The New Mexico statute, however, does not simply distinguish between resident veterans and non-veteran residents; it confers a benefit only on “established” resident veterans, i. e., those who resided in the State before May 8,1976. Ap-pellee and the State justify this distinction on the basis that those veterans who left their homes in New Mexico to fight in Vietnam, as well as those who settled in the State within the few years after thé war ended, deserve to be treated differently from veterans who make New Mexico their home after May 8, 1976. The legislature is said to have decided it owed a special responsibility to these “established” veterans.

Appellee and the State’s evaluation of this legislative judgment may be questioned on its own terms. Those who serve in the military during wartime inevitably have their lives disrupted; but it is difficult to grasp how New Mexico residents serving in the military suffered more than residents of other States who served, so that the latter would not deserve the benefits a State bestows for national military service. Moreover, the legislature provided this economic boon years after the dislocation occurred. Established state residents, by this time, presumably had become resettled in the community and the modest tax exemption hardly bears directly on the transition to civilian life long after the war’s end. Finally, the benefit of the tax exemption continues for the recipient’s life. The annual exemption, which will benefit this limited group of resident veterans long after the wartime disruption dissipated, is a continuing bounty for one group of residents rather than simply an attempt to ease the veteran’s return to civilian life.

Even assuming that the State may legitimately grant benefits on the basis of a coincidence between military service and past residence,11 the New Mexico statute’s distinction *622between resident veterans is not rationally related to the State’s asserted legislative goal. The statute is not written to require any connection between the veteran’s prior residence and military service.12 Indeed, the veteran who resided in New Mexico as an infant long ago would immediately qualify for the exemption upon settling in the State at any time in the future regardless of where he resided before, during, or after military service.

C

Stripped of its asserted justifications, the New Mexico statute suffers from the same constitutional flaw as the Alaska statute in Zobel.13 The New Mexico statute, by singling out previous residents for the tax exemption, rewards *623only those citizens for their “past contributions” toward our Nation’s military effort in Vietnam. Zobel teaches that such an objective is “not a legitimate state purpose.” 457 U. S., at 63. The State may not favor established residents over new residents based on the view that the State may take care of “its own,” if such is defined by prior residence. Newcomers, by establishing bona fide residence in the State, become the State’s “own” and may not be discriminated against solely on the basis of their arrival in the State after May 8, 1976. See, e. g., Vlandis v. Kline, 412 U. S. 441, 449-450, and n. 6 (1973); Shapiro v. Thompson, 394 U. S., at 632-633; Passenger Cases, 7 How. 283, 492 (1849) (Taney, C. J., dissenting).

The New Mexico statute creates two tiers of resident Vietnam veterans, identifying resident veterans who settled in the State after May 8, 1976, as in a sense “second-class citizens.” This discrimination on the basis of residence is not supported by any identifiable state interest; the statute is not written to benefit only those residents who suffered dislocation within the State’s borders by reason of military service. Zobel made clear that the Constitution will not tolerate a state benefit program that “creates fixed, permanent distinctions . . . between . . . classes of concededly bona fide residents, based on how long they have been in the State.” 457 U. S., at 59.14 Neither the Equal Protection Clause, nor this Court’s precedents, permit the State to prefer established resident veterans over newcomers in the retroactive apportionment of an economic benefit.

D

We decline appellants’ request to rule on the severability of the unconstitutional aspect of the New Mexico veterans’ tax *624exemption statute. If the fixed-date residence requirement, § 7-37-5(C)(3)(d), were excised from the statute, the exemption would be available to all current resident veterans who served the requisite 90 days during the Vietnam War and received honorable discharges. It is for the New Mexico courts to decide, as a matter of state law, whether the state legislature would have enacted the statute without the invalid portion. See, e. g., Zobel v. Williams, supra, at 64-65; Champlin Refining Co. v. Corporation Comm’n of Oklahoma, 286 U. S, 210, 234 (1932); State v. Spearman, 84 N. M. 366, 368, 503 P. 2d 649, 651 (App. 1972).

IV

We hold that the New Mexico veterans’ tax exemption statute violates ’the guarantees of the Equal Protection Clause of the Fourteenth Amendment. Accordingly, the judgment of the New Mexico Court of Appeals is reversed, and the case is remanded for proceedings not inconsistent with this opinion.

Reversed and remanded.

concurring.

I join the Court’s opinion for the reasons stated therein and in my concurring opinion in Zobel v. Williams, 457 U. S. 55, 65 (1982).

dissenting.

Vietnam veterans are, of course, a distinct minority of the population of New Mexico.1 The majority has decided to *625provide them with a special benefit that is not available to the average citizen. In my opinion, there can be no question about the constitutionality of that decision, and I believe it is equally clear that there is nothing invidious in the way the State has defined the class of veterans eligible for the benefit. The validity of the classification is unaffected by the form of the benefit or the date of enactment of the statute. It does not violate the Equal Protection Clause of the Fourteenth Amendment.

I

The New Mexico legislation that is challenged in this case provides a $2,000 property tax exemption to Vietnam veterans (or their unmarried surviving spouses) if the veteran was, among other requirements, a New Mexico resident prior, to May 8, 1976.2 N. M. Stat. Ann. §7-37^5(0 (1983). This 'legislation is consistent wdth the Equal Protection Clause if “the distinction it makes rationally furthers a legitimate state purpose.” Zobel v. Williams, 457 U. S. 55, 60 (1982).

Arguably, this statute raises two questions under the Equal Protection Clause: (1) is there a rational justification for treating the eligible veterans more favorably than the average citizen; and (2) if so, is there any rational justification *626for not offering the benefit to all veterans who then lived, or might thereafter live, in New Mexico?

The justification for providing a special benefit for veterans, as opposed to nonveterans, has been recognized throughout the history of our country. It merits restatement. First, the simple interest in expressing the majority’s gratitude for services that often entail hardship, hazard, and separation from family and friends, and that may be vital to the continued security of our Nation, is itself an adequate justification for providing veterans with a tangible token of appreciation. Second, recognition of the fact that military service typically disrupts the normal progress of civilian employment justifies additional tangible benefits — employment preferences, educational opportunities, subsidized loans, tax exemptions, or cash bonuses — to help overcome the adverse consequences of service and to facilitate the reentry into civilian society. A policy of providing special benefits for veterans’ past contributions has “always been deemed to be legitimate.”3

The historic justification would support a state decision to provide a benefit for all Vietnam veterans.4 This case, however, involves a challenge to a decision to provide a benefit *627for some, but not all, veterans residing in New Mexico. What is the justification for placing any limit on the class of eligible veterans? The most obvious answer is that the State’s resources are not infinite. The need to budget for the future is itself a valid reason for concluding that a limit should be placed on the size of the class of potential beneficiaries. And surely that limit may be defined in a way that is intended to direct finite state resources to those who may have a special need.

In this case, New Mexico’s legislation reflects, not only an expression of gratitude, but also an attempt to ameliorate the hardship Vietnam veterans experienced upon seeking to integrate or reintegrate themselves into New Mexican society. The transition from military to civilian life has always been a difficult one. That transition is furthered by a state decision to provide a benefit for those veterans who once had roots in the State and had returned, or decided to settle in the State, after their military service ended. New Mexico’s modest monetary benefit can be reasonably understood as both a tangible and symbolic “welcome home” to veterans returning to New Mexico from the Far East as well as to those deciding to establish their domiciles in the State for the first time. The legislation simply reflects and recognizes the State’s felt obligation to facilitate the difficult transition of veterans from the battlefields of Asia to civilian life in New Mexico.

Of course, the legislature might have crafted a more elaborate set of eligibility criteria, but since exclusion from the favored class merely places the ineligible veteran in the same class as the majority of the citizenry, there is no constitutional objection to the use of a simple, easily administered standard. The statutory requirement of residence before May 8,1976, is not a perfect proxy for identifying those Vietnam veterans seeking admission or readmission into New Mexican society, but “rational distinctions may be made with substantially less than mathematical exactitude.” New Orleans v. Dukes, 427 U. S. 297, 303 (1976).

*628HH HH

In my opinion, the validity of the State’s classification is not undermined by the fact that it takes the form of a modest annual tax exemption instead of a cash payment or gold medal. It is true that the continuing character of the exemption differentiates the eligible veteran from the rest of the citizenry over an extended period of time, but I fail to see how that fact bears on the rationality of the classification. If New Mexico had awarded gold medallions to all of its resident veterans on May 1, 1976, I believe it would be absurd for a veteran arriving in the State in 1981 to claim that he or she had a constitutional right either to a comparable medal or to have all other medal recipients return them to the State.

In like manner, New Mexico by this legislation has provided, in effect, a modest annuity for veterans who own real property. Again, it is surely rational'for the State to provide this form of assistance rather than a lump-sum cash bonus. To begin with, a one-time cash bonus would concentrate the fiscal burden of the veterans benefit in one budget year, perhaps preventing New Mexico from awarding any meaningful veterans benefit at all.5 Rather than providing a trivial token of esteem, the State may have decided to provide an annual and therefore recurring benefit which would, over time, amount to a more significant recognition of service to. returning veterans. The perennial character of its tax exemption may have been especially important in the minds of New Mexico’s legislators if their objective was to provide a symbolic expression of New Mexico’s invitation to rejoin the community on a long-term basis: The recurring form of the benefit provided symbolic reassurance of state support year *629after year. In so doing, the State might sensibly have expected to instill in returning Vietnam veterans a sense of security and peace of mind after the tumult of that conflict.

For these reasons, New Mexico’s statute is not at all like the Alaska dividend program struck down in Zobel v. Williams, 457 U. S. 55 (1982). The dividend program involved in Zobel created “an ever-increasing number of perpetual classes of concededly bona fide residents, based on how long they have been in the State.” Id., at 59. Every recent arrival was treated less favorably than those who had arrived earlier. The vast majority of dividend recipients were thus treated more favorably than the newly arrived minority. In this case, in contrast, the alleged victim of the discrimination is being treated exactly like the vast majority of New Mexico’s residents. In Zobel, the program had no rational justification other than a purpose to allocate a cash surplus among the majority of the citizenry on the basis of the duration of their residence in the State. In this case, the duration of the veteran’s residence is irrelevant and the distribution to the members of the favored class is supported by a legitimate state interest.6 There is a world of difference between a decision to provide benefits to some, but not all, veterans and a decision to divide the entire population into a multitude *630of classes differentiated only by length of residence. The State’s refusal to provide appellant with a veteran’s benefit has not branded him with any badge of inferiority. He has not been treated as a “second class citizen” in any sense. Rather, he has merely received precisely the same treatment as the vast majority of the residents of New Mexico.

f — I HH HH

The Court finds constitutionally significant the fact that the May 8, 1976, cut-off date was not enacted until 1983,7 and in its understanding of the application of the statute to a veteran who had merely resided in New Mexico as an infant. See ante, at 622. Neither point is valid.

Tellingly, the initial version of New Mexico’s property tax exemption for Vietnam-era veterans — which was enacted in 1973 — had an effective date of January 1, 1975. Even if the Court’s concern with “retroactive apportionment of an economic benefit,” ante, at 623, were valid — and the constitutional defect in retroactivity is never explained — the originating legislation simply was not retroactive.8 Thus, the Court’s point at best is limited to the state legislature’s decision on two subsequent occasions to liberalize the statutory requirements by extending the cut-off date for eligibility. But the Court does not — and cannot — explain why New *631Mexico’s belated recognition that its veterans’ assistance program was incomplete9 renders it ipso facto unconstitutional.

Even if New Mexico’s action were wholly retroactive I would find no constitutional defect. The New Mexico Legislature could reasonably conclude that for many Vietnam veterans the transition from military service to civilian life in New Mexico was still incomplete. New Mexico could further reasonably conclude that some assistance, at once tangible and symbolic, was required to complete the task. I do not think it unconstitutional for New Mexico to presume that Vietnam veterans who arrived in that State more than a year after the end of the Vietnam epoch had successfully readjusted to civilian life in a sister State prior to migrating to New Mexico.10 Under this view, appellant simply was not in New Mexico when the conditions justifying the assistance were deemed to exist. The late-arriving Vietnam veteran is treated as well as the overwhelming majority of immigrants to the State; until today’s decision, I would not have thought that the Constitution required New Mexico to do more.

In an attempt to highlight the asserted irrationality of the New Mexico statute, the Court asserts that an unquantifiable few late-in-coming Vietnam veterans might qualify for the property tax exemption:

“[T]he veteran who resided in New Mexico as an infant long ago would immediately qualify for the exemption upon settling in the State at any time in the future *632regardless of where he resided before, during, or after military service.” Ante, at 622.

The New Mexico Court of Appeals, however, did not adopt this construction of the statute: it did not reach this state-law question because appellant did not have standing to raise it.11 There is thus nothing in the record to support the Court’s assumption that if a veteran who resided in New Mexico as an infant should now return to the State, he or she would qualify for the tax exemption. It hardly befits a federal court that is committed to a policy of avoiding constitutional questions whenever possible to volunteer an unnecessary interpretation of a state statute in order to create a constitutional infirmity. But there is a more fundamental defect in the Court’s argument — indeed, in its entire analysis.

Even if there are a few isolated cases in which the general classification produces an arbitrary result, that is surely not a sufficient reason for concluding that the entire statute is unconstitutional:

"The mere fact that an otherwise valid general classification appears arbitrary in an isolated case is not a sufficient reason for invalidating the entire rule. Nor, indeed, is it a sufficient reason for concluding that the application of a valid rule in a hard case constitutes a *633violation of equal protection principles. We cannot test the conformance of rules to the principle of equality simply by reference to exceptional cases.” Caban v. Mohammed, 441 U. S. 380, 411-412 (1979) (Stevens, J., dissenting) (footnotes omitted).

See also Vance v. Bradley, 440 U. S. 93, 108 (1979); Califano v. Jobst, 434 U. S. 47, 56-58 (1977); Dandridge v. Williams, 397 U. S. 471, 485 (1970).

New Mexico has elected to express its gratitude to the veterans of the Vietnam conflict by providing a modest tax exemption for those who resided in the State before May 8, 1976. Those veterans who arrived thereafter are treated exactly like the nonveterans who constitute the majority of the State’s population. In my opinion, there is no substance to the claim that this classification violates the principle of equality embodied in the Equal Protection Clause of the Fourteenth Amendment to the Constitution.12

Accordingly, I respectfully dissent.