Nyquist v. Mauclet
Headline: New York rule blocking resident noncitizens from state college scholarships and loans is struck down, making many permanent resident students eligible for the same higher-education aid as citizens.
Holding:
- Makes resident permanent noncitizen students eligible for state scholarships, tuition awards, and loans.
- Stops states from excluding resident aliens from higher-education aid based solely on citizenship.
- May slightly increase program costs but requires equal treatment for taxpaying resident noncitizens.
Summary
Background
The State of New York had a law that denied some noncitizen residents access to state financial help for college unless they applied for or declared intent to seek U.S. citizenship. Two long-term resident students — one from France who would not give up his foreign citizenship, and one from Canada who also declined to naturalize — were told they could not receive scholarships, tuition awards, or student loans. They sued and won in federal district courts.
Reasoning
The Court examined whether the rule unfairly singled out resident noncitizens. It relied on earlier decisions saying state rules based on alien status get close scrutiny. The majority concluded that even though the statute allowed eligibility for aliens who applied or declared intent, it still discriminated against aliens as a class. New York’s arguments — that the rule encouraged naturalization or focused benefits on future voters — were not sufficient to justify excluding resident noncitizens who otherwise contribute to the state.
Real world impact
As a result, New York may not deny scholarships, tuition awards, or student loans to resident noncitizens solely because they refuse to become citizens. The ruling affects the State’s three main aid programs and requires states to treat taxpaying resident noncitizens the same as citizens for these benefits. The Court affirmed the district courts’ injunctions against enforcing the citizenship bar; this is a final decision on the constitutional claim in these cases.
Dissents or concurrances
Several Justices disagreed, arguing the statute drew a reasonable line between aliens who will become citizens and those who will not, and that states may rationally favor citizens when distributing limited funds.
Opinions in this case:
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