Foley v. Connelie case brief

Foley v. Connelie case brief summary
435 U.S. 291 (1978)

CASE SYNOPSIS

Appellant sought review of a declaratory judgment from a three-judge panel of the United States District Court for the Southern District of New York in favor of appellee state officials holding that N.Y. Exec. Law § 215(3) (1972), which provided that no person could be appointed to the state police force unless he was a citizen of the United States, was constitutional.

DISCUSSION

• The Supreme Court affirmed a judgment holding that N.Y. Exec. Law § 215(3) (1972), which provided that no person could be appointed to the state police force unless he was a citizen of the United States, was constitutional. 
• Appellant had sought a declaratory judgment that the state's exclusion of aliens from its police force violated the Equal Protection Clause of U.S. Constitutional Amendment XIV. 
• The Court concluded that the state's obligation to preserve the political community included reserving the right to govern to citizens. 
• Each challenged position was required to be examined to determine whether it involved discretionary decisionmaking, or execution of policy, which substantially affected members of the political community. 
• The broad powers vested in police officers affected members of the public significantly, and often in the most sensitive areas of life. 
• Police officers very clearly participated directly in the execution of broad public policy. 
• The police function was one where citizenship bore a rational relationship to the special demands of the particular position. 
• Therefore, a state could restrict the performance of this important public responsibility to citizens.

CONCLUSION
The Supreme Court affirmed a judgment holding that the challenged law, which excluded aliens from the state police force, was constitutional. As police officers participated directly in the execution of broad public policy, citizenship bore a rational relationship to the special demands of police officer positions.