Foley v. Connelie
Foley v. Connelie is a significant Supreme Court case concerning the eligibility of resident aliens for employment in state law enforcement positions. The case arose when Edmund Foley, a legally admitted resident alien, was denied the opportunity to take the competitive examination to become a New York State trooper due to a law stipulating that only U.S. citizens could be appointed. Foley challenged this law, arguing that it violated the equal protection clause of the Fourteenth Amendment. In a 6-3 ruling, the Supreme Court upheld the law, stating that states have a historical authority to exclude aliens from certain government roles, viewing law enforcement as a fundamental governmental function.
The Court distinguished this case from previous rulings, such as Graham v. Richardson, by applying a more lenient standard of review for classifications based on alienage, allowing such distinctions as long as they had a rational relationship to a legitimate governmental interest. This decision set a precedent for future cases, including Ambach v. Norwick, which continued to support restrictions on public employment for non-citizens. Overall, Foley v. Connelie highlights ongoing debates about citizenship, rights, and the role of government in defining eligibility for public service.
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Foley v. Connelie
The Case: U.S. Supreme Court decision on rights of immigrants
Date: Decided on March 22, 1978
Significance:Upholding a state law that discriminated against aliens, the Supreme Court in the Foley decision departed from a previous decision based on strict scrutiny, thereby making it much more likely that similar policies would be upheld.
A legally admitted resident alien, Edmund Foley applied for a position as a New York State trooper. A state law, however, provided that only U.S. citizens could be appointed to the state’s police force. When Foley was denied the right to take the competitive examination, he went to court to argue that the law violated the equal protection clause of the Fourteenth Amendment.
In a 6-3 decision, the Supreme Court emphasized that the states had exercised a “historical power to exclude aliens from participation in its democratic political institutions,” and that the police function was “one of the basic functions of government.” In contrast to the landmark precedent case Graham v. Richardson (1971), the Court did not assess the law according to the demanding standard of strict scrutiny. In contrast to classifications based on race, the majority of the justices accepted the premise that a classification based on alienage was acceptable so long as there was a rational relationship between the classification and a valid governmental interest. In a subsequent decision, Ambach v. Norwick (1979), the Court used the same standard of review in upholding alienage restrictions for teachers in the public schools.
Bibliography
Bosniak, Linda. The Citizen and the Alien: Dilemmas of Contemporary Membership. Princeton, N.J.: Princeton University Press, 2008.
Epstein, Lee, and Thomas Walker. Constitutional Law for a Changing America: Rights, Liberties, and Justice. 6th ed. Washington, D.C.: CQ Press, 2006.