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In the 1970s, the United States Supreme Court took up a series of cases involving state laws that discriminated, in some way, against noncitizens. One such case, Ambach v. Norwick, 441 U.S. 68 (1979), dealt with a New York state law barring noncitizens from being certified as public-school teachers – unless they sought citizenship.
A British national named Susan Norwick, who was married to a U.S. citizen, requested certification as a teacher in the state. Although Norwick was eligible for U.S. citizenship, she did not want to pursue it. As a result, New York would not certify Norwick as a teacher.
Norwick sued New York’s commissioner of education, Gordon Amback, to challenge the denial. The case was ultimately appealed to the United States Supreme Court.
The issue before the Court was whether New York could constitutionally refuse to employ noncitizens as public-school teachers. Under the Court’s equal-protection jurisprudence, classifications based on alienage are generally suspect.
However, because public-school teaching was a legitimate governmental function, the Court subjected the law to only rational-basis review. The Court concluded that citizenship was rationally related to the legitimate goal of teaching in public school.
Therefore, the Court upheld the New York law.