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Law School Case Brief

Ambach v. Norwick - 441 U.S. 68, 99 S. Ct. 1589 (1979)

Rule:

N.Y. Ed. Law § 3001(3) (1970) forbids certification as a public school teacher of any person who is not a citizen of the United States, unless that person has manifested an intention to apply for citizenship.

Facts:

Appellees’ applications for teaching certificates were denied despite the fact that they have complied with all the educational requirements that New York State had set out for certification as a public school teacher. However, they consistently refused to seek United States citizenship in spite of their eligibility to do so. The district court ruled that N.Y. Educ. Law § 3001 violated the Equal Protection Clause and discriminated against the teachers.

Issue:

Does the law that required the applicant teachers to obtain citizenship violate of the Equal Protection Clause?

Answer:

No.

Conclusion:

The Court found that because public school teachers fell within the previously recognized "governmental function" principle, the United States Constitution required only that a citizenship requirement applicable to teaching in the public schools have a rational relationship to a legitimate state interest. The Court found that the State had a legitimate state interest in furthering educational goals, and the restriction was carefully framed to serve its purpose, as it barred from obtaining a New York teaching credential only those aliens who had demonstrated their unwillingness to obtain citizenship. Therefore, the statute did not violate the Equal Protection Clause.

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