Sugarman v. Dougall Case Brief

Why is the case important?

A New York statute excluded aliens from all government civil service jobs filled by competitive examination. It did not apply to higher office positions, however. The Appellees, Dougall and others (Appellees), challenged the constitutionality of the statute.

Facts of the case

Patrick Dougall was a federally registered resident alien. He was employed by a nonprofit organization that was absorbed into the Manpower Career and Development Agency (MCDA) of New York City’s Human Resources Administration. He was ineligible for employment by the city under Section 53 of the New York Civil Service Law because he was a noncitizen. He was terminated for this reason alone. Dougall and other noncitizens who were terminated under Section 53 challenged the statute in the United States District Court for the Southern District of New York, which held the statute unconstitutional. New York appealed the decision.

Question

Was New York’s flat statutory prohibition against the employment of aliens in its competitive civil servant jobs unconstitutional?

Answer

Yes. The judgment of the District Court is affirmed.
Justice Harry Blackmun (J. Blackmun) stated that a flat ban on the employment of aliens in positions that have little or no relationship to the State’s legitimate interest cannot withstand close judicial scrutiny under the Equal Protection Clause of the United States Constitution.
The Appellant, the state of New York’s (Appellant), justifications prove too much and too little. The State’s prohibition applies to jobs, e.g., sanitation workers, typists, where loyalty to the State isn’t essential. On the other hand, the statute does not apply to jobs for which loyalty to the State is indispensable. Aliens are a discrete insular minority, therefore, a classification based on alienage commands a closer means to ends fit then the New York statute provides.

Conclusion

Classifications based on alienage are subject to close judicial scrutiny. The Court looked to the substantiality of the state’s interest in enforcing the statute and to the narrowness of the limits within which the discrimination was confined.

  • Case Brief: 1973
  • Appellant: Jule M. Sugarman, Administrator, New York City Human Resources Administration et al.
  • Appellee: Patrick McL. Dougall et al.
  • Decided by: Burger Court

Citation: 413 US 634 (1973)
Argued: Jan 8, 1973
Decided: Jun 25, 1973