Truax v. Raich

1915-11-01

Headline: Court struck down an Arizona law that barred many lawful non‑citizen residents from employment in most businesses, protecting immigrant workers and stopping states from excluding admitted aliens from ordinary jobs.

Holding: The Court held that Arizona’s employment quota law discriminating against noncitizens violated the Fourteenth Amendment’s equal protection guarantee and could not be enforced against lawful resident aliens.

Real World Impact:

Stops states from barring admitted noncitizens from most private jobs.
Protects immigrant workers from being forced out solely due to alienage.
Limits state authority to exclude lawful residents from ordinary occupations.

Topics: employment discrimination, immigrant workers, equal protection, state labor rules

Summary

Background

Mike Raich, a native of Austria lawfully living in Arizona, worked as a cook for a restaurant owner who employed nine people. Arizona voters adopted a law requiring employers with more than five workers to have at least 80% be qualified electors or native‑born citizens. After the law passed, Raich’s employer said he would be discharged to meet the law’s quota, and Raich sued state officers and his employer asking a federal court to block enforcement of the law as unconstitutional.

Reasoning

The Court addressed whether a State may deny lawful resident aliens equal protection by excluding them from ordinary employment. The majority held that aliens lawfully admitted and living in a State are “persons” entitled to equal protection. The Arizona measure clearly targeted aliens as such and covered nearly all private businesses. The Court found no special public interest justifying that broad exclusion. It also noted that control of immigration belongs to the Federal Government, so a State cannot effectively deny admitted aliens the ability to live by refusing them ordinary work. For those reasons, the law was held invalid and could not be enforced.

Real world impact

The decision prevents Arizona from enforcing the quota law and protects lawfully admitted noncitizen residents from being forced out of ordinary jobs solely because of their alienage. Employers, immigrant workers, and state officials cannot rely on this statute to exclude aliens from most fields of private employment.

Dissents or concurrances

Justice McReynolds dissented, arguing the suit was effectively against the State and that federal courts should not enjoin state criminal laws under the Eleventh Amendment and related precedents.