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Keywords

plaintiffdefendantstatuteburden of proofwilldue processgood faith
statutedue processsustainedappellee

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Law Students Civil Rights Research Council, Inc. v. Wadmond, 401 U.S. 154, 91 S.Ct. 720, 27 L.Ed.2d 749

Facts

The case arose from two consolidated actions initiated by organizations and individuals representing law students and graduates seeking admission to the New York Bar. They named as defendants the Committees on Character and Fitness and their members, as well as judges from two appellate divisions. The plaintiffs argued that the statutes, rules, and screening procedures were invalid, claiming they imposed unconstitutional burdens on applicants' rights to free speech and association. The three-judge District Court found some aspects of the questionnaire intrusive but upheld the overall validity of the admission process.

This case involves a broad attack, primarily on First Amendment vagueness and overbreadth grounds, upon this system for screening applicants for admission to the New York Bar.

Issue

Does the New York rule requiring applicants for the Bar to prove their belief in the form of government of the United States and loyalty to it violate the First Amendment and due process rights?

The Supreme Court, Mr. Justice Stewart, held that New York rule directing committees on character and fitness not to certify applicant for admission to Bar unless he proves he believes in form of the government of the United States and is loyal to such government does not violate due process or impermissibly inquire into applicant's political beliefs.

Rule

The New York Judiciary Law requires that applicants for admission to the Bar must demonstrate good moral character and general fitness, which includes a requirement to show belief in the U.S. government and loyalty to it, as interpreted by state authorities.

The ‘character and general fitness' requirement for admission to the New York Bar is not violative of the Constitution.

Analysis

The Supreme Court analyzed the New York rule in light of its interpretation by state authorities, which clarified that the requirement did not impose a burden of proof on applicants. The terms 'form of the government of the United States' and 'government' were construed to refer solely to the Constitution, and 'belief' and 'loyalty' were defined as a willingness to take the constitutional oath in good faith. The court found that the screening process did not chill constitutional freedoms and was a legitimate inquiry into the character and fitness of applicants.

The requirement has been construed by appellees to encompass no more than ‘dishonorable conduct relevant to the legal profession.’

Conclusion

The Supreme Court affirmed the lower court's ruling, concluding that the New York rule and the screening procedures for Bar admission did not violate constitutional rights.

Held: 299 F.Supp. 117, affirmed.

Who won?

The State of New York prevailed in the case, as the Supreme Court upheld the constitutionality of the Bar admission requirements and the screening process, finding no infringement on applicants' rights.

The three-judge District Court found certain items on the questionnaire so vague, overbroad, and intrusive on applicants' privacy as to be of doubtful constitutional validity, but upheld the statute and rules as valid on their face, and with the exceptions noted, sustained the validity of the procedure.

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