Ambach v. Norwick

Brief Fact Summary.

Two foreign nationals who resided in the U.S. for many years and were married to U.S. citizens did not apply for citizenship. Both applied for certification as public school teachers in the state of New York. A New York law prohibited the certification of non-citizen teachers who had not sought citizenship. Both applications were denied on that ground.

Synopsis of Rule of Law.

It is constitutional to prohibit non-citizens from teaching in public schools because it is a governmental function.

Facts.

Two foreign nationals who had resided in the U.S. for many years and were married to U.S. citizens. Both were eligible for citizenship, but did not apply. Both applied for certification as public school teachers in the state of New York. A New York law prohibited the certification of non-citizen teachers who had not sought citizenship. Both applications were denied certification solely on that ground.

Issue.

Did the New York statute violate the Equal Protection Clause?

Held.

No, the New York statute did not violate the Equal Protection Clause.

Dissent.

Justice Blackmun

The New York classification is irrational. It is not better to employ a poor citizen-teacher than an excellent resident alien teacher. The state has other means by which to responsibly select its teachers, wholly apart from citizenship.

Discussion.

The exclusion of aliens from governmental positions does not invite as demanding scrutiny from this court. Public education fulfills a fundamental obligation of government. The importance of public schools in the preparation of individuals for participation as citizens and in the preservation of the values on which our society rests, has long been recognized by this Court. Teachers play a critical role in developing students’ attitudes toward government and understanding of the role of citizens in our society. They have wide discretion over the way course material is communicated to students. Also, teachers serve as role models for their students. Thus, a teacher has opportunity to influence the attitudes of students toward government, the political process, and a citizen’s social responsibilities. This influence is crucial to the continued good health of a democracy.

The state of New York has a legitimate state interest in furthering these educational goals. Moreover, the New York statute bears a rational relationship to this interest because it is carefully framed to serve this purpose, barring from teaching only those aliens who have demonstrated their unwillingness to obtain U.S. citizenship.