Fre Le Poole Griffiths was a citizen of the Netherlands who came to the United States in 1965, married a United States citizen in 1967, and became a resident of Connecticut. After graduating from law school, she applied in 1970 for permission to take the Connecticut bar examination. The County Bar Association found her qualified in all respects except that she was not a United States citizen, as required by Rule 8(1) of the Connecticut Practice Book. On that basis alone, she was denied permission to take the examination.
Issue
Whether Connecticut's rule requiring United States citizenship for admission to the bar violates the Equal Protection Clause of the Fourteenth Amendment by excluding resident aliens from the practice of law.
Rule
Classifications based on alienage are inherently suspect and subject to close judicial scrutiny. To justify such a classification, the State must show that its purpose is constitutionally permissible and substantial, and that use of the classification is necessary to accomplish that purpose or safeguard that interest.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Colorado allows graduates of accredited law schools to sit for its bar exam only if they are United States citizens. Elena Markovic, a lawful permanent resident living in Denver, meets every educational and character requirement, but the state board rejects her application solely because she is not a citizen.
If Elena challenges the rule under the Equal Protection Clause, what is the strongest basis for holding the rule unconstitutional?
Explanation. The majority held that classifications based on alienage are inherently suspect and receive close judicial scrutiny. The State bears a heavy burden to show a constitutionally permissible and substantial interest, and that use of the alienage classification is necessary to accomplish or safeguard that interest. Although a State may regulate bar admission and assess fitness, a blanket citizenship bar for an otherwise qualified resident alien fails that test.