Wednesday, November 13, 2013

Cabell v. Chavez-Salido case brief

Cabell v. Chavez-Salido case brief summary
454 U.S. 432 (1982)


CASE SYNOPSIS
Appellants, the County of Los Angeles and certain of its officials, sought review of a decision of a three-judge panel of the United States District Court for the Central District of California, which declared that appellees, lawfully admitted permanent resident aliens, were unconstitutionally excluded from positions as state probation officers by a statutory citizenship requirement contained in Cal. Gov't Code § 1031(a).

CASE FACTS
Appellees, lawfully resident aliens, brought an action against appellants, the County of Los Angeles and certain of its officials, seeking declaratory and injunctive relief after they were denied positions as probation officers because of a statutory citizenship requirement for peace officers contained in Cal. Gov't Code § 1031(a).


DISCUSSION

  • On appeal from a judgment declaring the statute violated the Equal Protection Clause, U.S. Constitutional amend. XIV, the Supreme Court reversed, noting that while economic restrictions on lawfully resident aliens were subject to heightened judicial scrutiny, such scrutiny was out of place as to restrictions that primarily served a political function. 
  • The Court then applied a two-part evaluation process to determine that the challenged restriction served a political rather than economic function and that the classification in question was sufficiently tailored to attain a legitimate political goal, which was to ensure that law enforcement be performed by those having the fundamental legal bond of citizenship. 
  • Specifically, a citizenship requirement was held appropriate for probation officers, who had broad power to exercise coercive force over individuals.

CONCLUSION
The court reversed the judgment declaring unconstitutional appellants' statutory citizenship requirement for peace officers, and the case was remanded.

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