## Facts

- California law required U.S. citizenship for any “public officers or employees declared by law to be peace officers.”
- California designated probation officers and deputy probation officers as “peace officers.”
- Lawfully admitted permanent resident aliens applied for deputy probation officer positions in Los Angeles County.
- The applicants were rejected solely because they were not U.S. citizens.
- The rejected applicants sued state and county officials for declaratory and injunctive relief, alleging the citizenship requirement violated the Equal Protection Clause.

## Issues

1. Whether a state law requiring U.S. citizenship for probation officers violates the Equal Protection Clause when applied to lawful permanent resident aliens.
2. Whether probation officers fall within the “political function” exception permitting certain state alienage-based employment restrictions.

## Decision

- The Supreme Court reversed the district court in a 5–4 decision.
- The Court held the statutory citizenship requirement for probation officers was constitutional.
- The Court concluded probation officers sufficiently exercise the sovereign’s coercive police power over individuals to justify limiting the positions to citizens under the political function exception.
- The dissent would have treated the jobs as ordinary public employment, applied strict scrutiny, and invalidated the requirement.

## Legal Principles

- State alienage classifications affecting economic interests generally trigger strict scrutiny under equal protection.
- Strict scrutiny is inappropriate where the restriction primarily serves a political function connected to self-government and the exercise of sovereign authority.
- In assessing a claimed political function justification, courts examine: (1) whether the classification is specifically drawn (not substantially overinclusive or underinclusive), and (2) whether it is applied to positions that are elective or important nonelective posts involving the exercise of sovereign power.
- Positions involving direct, broad coercive authority over individuals (even with a limited jurisdictional reach) may be reserved to citizens consistent with equal protection.

## Conclusion

The Court upheld California’s citizenship requirement for probation officers, reasoning that their designation as peace officers and their broad supervisory and coercive authority over probationers place the job within the political function exception to strict scrutiny for state alienage classifications.


Cabell v. Chavez-Salido, 454 U.S. 432 (1982)