## Facts

- Bryan M. Hansen, a Minnesota resident, graduated in 1977 from Western State University College of Law in California.
- Minnesota required bar-exam applicants to graduate from an “approved law school,” defined as provisionally or fully approved by the American Bar Association (ABA).
- Western State was not ABA-approved and had never sought ABA accreditation, though it was accredited by the California Committee of Bar Examiners and by a regional accreditor.
- Hansen previously attended an ABA-approved law school briefly and was advised to remain partly because of ABA approval, but he transferred to Western State.
- The Minnesota State Board of Law Examiners denied Hansen permission to sit for the Minnesota bar examination based on the ABA-approval requirement.
- After a formal hearing process (which Hansen chose not to attend), the Board reaffirmed its denial.
- Hansen sought review, arguing the ABA-approval requirement violated the Fourteenth Amendment’s Due Process and Equal Protection Clauses.

## Issues

1. Whether conditioning eligibility to sit for the bar examination on graduation from an ABA-approved law school violates substantive due process as arbitrary or unreasonable.
2. Whether the ABA-approval requirement violates equal protection by irrationally distinguishing between graduates of ABA-approved and non-ABA-approved law schools.

## Decision

- The court affirmed the Board’s denial of Hansen’s application to sit for the bar examination.
- The court upheld the ABA-accredited-law-school requirement as constitutional.
- Applying rational-basis review, the court concluded the rule reasonably served the state’s interest in assuring minimum competence and protecting the public, courts, and profession.
- The court held the state could rely on ABA accreditation as a uniform proxy for educational quality rather than create a separate, school-by-school evaluation system.
- The court rejected arguments that alternative accreditation or individualized assessments were constitutionally required.

## Legal Principles

- A state supreme court has inherent authority to regulate admission to the bar and may delegate administrative functions to a board of law examiners.
- Under rational-basis review, bar-admission prerequisites are valid if reasonably related to legitimate regulatory objectives, including ensuring minimum legal competence.
- Conditioning bar-exam eligibility on graduation from an ABA-approved law school does not, by itself, violate substantive due process.
- Distinguishing between graduates of ABA-approved and non-ABA-approved schools does not violate equal protection absent a suspect classification or infringement of a fundamental right, so long as the distinction is rationally related to legitimate goals.
- The Constitution does not require a state to adopt the least restrictive or most individualized admission standard if the chosen rule is reasonable.

## Conclusion

The court held that Minnesota’s requirement that bar applicants graduate from an ABA-approved law school as a prerequisite to sitting for the bar examination is a rational, constitutional means of ensuring minimum educational quality and does not violate due process or equal protection.


In re Application of Hansen, 275 N.W.2d 790 (Minn. 1978)