Cabell v. Chavez-Salido

Background

Three lawful permanent resident aliens applied for deputy probation officer jobs in Los Angeles County but were denied because California law requires peace officers to be U.S. citizens. The applicants sued, and a three-judge federal district court held the citizenship rule unconstitutional both on its face and as applied. California's statutes place probation officers in the statutory category of "peace officers" and require citizens for those positions.

Reasoning

The Supreme Court examined prior cases about state restrictions on aliens and distinguished economic from political functions. It concluded that some public jobs that involve sovereign authority may be limited to citizens. The Court held that probation officers exercise important sovereign powers — including arrest authority, supervision, and discretionary decisions affecting probationers — and therefore fall within the category of positions that a State may reserve for citizens. Because the statutory scheme shows a unifying law-enforcement purpose and a substantial fit with that goal, the Court reversed the district court's facial and as-applied invalidation and sent the case back for proceedings consistent with its ruling.

Real world impact

The decision means California and other States can enforce citizenship requirements for probation officers and similar peace-officer positions. Lawful resident noncitizens who want those jobs may be barred unless they naturalize. The ruling does not address aliens here unlawfully or nonresident aliens. The opinion leaves open challenges to other occupations covered by the statute and signals that courts will examine whether a job truly involves sovereign authority.

Dissents or concurrances

Justice Blackmun, joined by three colleagues, dissented. He argued the statute was historically ad hoc and overbroad, that probation officers' duties are supervised and do not justify a blanket ban on lawful resident aliens, and that the District Court's finding that the law was unconstitutional should stand.