Sugarman v. Dougall

413 U.S. 634, 93 S. Ct. 2842 (1973)

 

RULE:

Aliens as a class are a prime example of a discrete and insular minority and classifications based on alienage are subject to close judicial scrutiny. A state's power to apply its laws exclusively to its alien inhabitants as a class is confined within narrow limits. Courts therefore look to the substantiality of the state's interest in enforcing the statute in question, and to the narrowness of the limits within which the discrimination is confined.

FACTS:

Federally registered resident aliens filed a class action when, because of their alienage, they were discharged from their competitive civil service positions with New York City. The aliens challenged the constitutionality of N.Y. Civ. Serv. Law § 53, which denied all aliens the right to hold positions in New York's classified competitive civil service for being violative of the Fourteenth Amendment and the Supremacy Clause of the U.S. Constitution. A defense motion to dismiss for want of jurisdiction was entered by appellants. The lower court ruled that the statute violated the Fourteenth Amendment and the Supremacy Clause and granted injunctive relief. 

ISSUE:

Is the statute discharging resident aliens from their competitive civil service positions violative of the Fourteenth Amendment and the Supremacy Clause of the U.S. Constitution?

ANSWER:

Yes.

CONCLUSION:

The Court affirmed the lower court's decision and determined that aliens as a class were a prime example of a discrete and insular minority. According to the Court, classifications based on alienage were subject to close judicial scrutiny. The Court looked to the substantiality of the state's interest in enforcing the statute and to the narrowness of the limits within which the discrimination was confined. The Court concluded that § 53 was unconstitutional because it violated the Equal Protection Clause in view of its breadth and imprecision in the context of the state's interest.

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