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Case Basics
Docket No. 
Jule M. Sugarman, Administrator, New York City Human Resources Administration et al.
Patrick McL. Dougall et al.
(First Assistant Attorney General of New York, argued the cause for the appellants)
(argued the cause for the appellees)
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.


Did Section 53 of the New York Civil Service Law violate the Equal Protection Clause of the Fourteenth Amendment?

Decision: 8 votes for Dougall, 1 vote(s) against
Legal provision: Equal Protection

Yes. In an 8-1 decision, the Court affirmed the District Court and held the statute unconstitutional. Justice Harry A. Blackmun, writing for the majority, recognized New York's "interest in establishing its own form of government" and having civil servants "of undivided loyalty.” However, Section 53's citizenship restriction was imprecise and "swep[t] indiscriminately." Since it could prohibit noncitizens from jobs in a way that did not further the state interest, the distinction it made between citizens and aliens violated the Equal Protection Clause under Graham v. Richardson.

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SUGARMAN v. DOUGALL. The Oyez Project at IIT Chicago-Kent College of Law. 01 March 2015. <>.
SUGARMAN v. DOUGALL, The Oyez Project at IIT Chicago-Kent College of Law, (last visited March 1, 2015).
"SUGARMAN v. DOUGALL," The Oyez Project at IIT Chicago-Kent College of Law, accessed March 1, 2015,