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Law School Case Brief

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


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.


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.


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




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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