Wednesday, November 13, 2013

Ambach v. Norwick case brief

Ambach v. Norwick case brief summary
441 U.S. 68 (1979)

Appellant, the state commissioner of education, sought review of a judgment by the United States District Court for the Southern District of New York, holding that N.Y. Educ. Law § 3001, discriminated, in violation of the Equal Protection Clause, against appellees, prospective teachers who were aliens.

Appellees both met all of the educational requirements that New York State had set out for certification as a public school teacher, but appellees consistently refused to seek United States citizenship in spite of their eligibility to do so. Appellees' applications for teaching certificates were denied because of appellees' failure to meet the requirements of N.Y. Ed. Law § 3001(3).


  • 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 that § 3001(3)'s restriction was carefully framed to serve its purpose, as it barred from teaching only those aliens who had demonstrated their unwillingness to obtain citizenship. 
  • Therefore, the statute did not violate the Equal Protection Clause.

The Court reversed, holding that the statute did not violate the Equal Protection Clause because the statute's citizenship requirement bore a rational relationship to a legitimate state interest.

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