In Sosna v. Iowa, 419 U.S. 393, 402, 42 L. Ed. 2d 532, 95 S. Ct. 553 (1975), the plaintiff challenged a one- year residency requirement for obtaining a divorce and sought to maintain a class action. However, by the time the case reached the Supreme Court, the plaintiff had met the residency requirement. The Supreme Court noted that "because of the passage of time, no single challenger will remain subject to the statute's restrictions for the period necessary to see such a lawsuit to its conclusion." Id. at 400. The Court held that the plaintiff could therefore remain as the named plaintiff in the class action. The Court cautioned, however, that "the same exigency that justifies this doctrine serves to identify its limits." Id. at 402.