## Facts

- New York Education Law § 3002 required teachers and professors in public schools and in tax-exempt private educational institutions to take an oath to support the U.S. and New York Constitutions and to faithfully discharge their duties.
- Adelphi University was a private, nonprofit university whose real property was tax-exempt under New York law.
- State education officials determined in 1966 that Adelphi had not been obtaining the § 3002 oath from faculty and directed the university to comply.
- Adelphi requested that faculty sign the statutory oath.
- Twenty-seven faculty members refused to sign and sued the Board of Regents, the Commissioner of Education, and Adelphi, seeking injunctive relief and a declaration that § 3002 and the oath were unconstitutional.
- The plaintiffs asserted violations of rights secured by the First and Fourteenth Amendments, including claims that the oath burdened speech and association and was void for vagueness.

## Issues

1. Whether requiring faculty at a tax-exempt private university to take an oath to support the federal and state constitutions and faithfully perform their duties violates the First Amendment as applied through the Fourteenth Amendment.
2. Whether the statutory oath is unconstitutionally vague under due process principles.

## Decision

- A three-judge district court upheld § 3002 and the oath requirement as constitutional.
- The court concluded the oath was an affirmative pledge of constitutional support and faithful performance, not an ideological test or restriction on expression.
- The court rejected the vagueness challenge, finding the oath’s language sufficiently clear.
- The complaint was dismissed and injunctive relief was denied.

## Legal Principles

- A state may condition teaching employment in public and tax-exempt private educational institutions on a simple, affirmative oath to support the U.S. and state constitutions and to perform professional duties.
- An oath is more likely to be constitutional when it does not compel disclaimers of belief or association, does not impose political orthodoxy, and does not restrict political or philosophical expression.
- Due process vagueness concerns are minimized when oath terms are common, comprehensible, and do not create uncertain standards that chill protected speech or association.

## Conclusion

The court sustained New York’s faculty oath requirement as a limited, affirmative assurance of constitutional allegiance and professional performance, holding it neither infringed protected expression nor failed for vagueness, and therefore dismissed the professors’ suit to block enforcement.


Knight v. Bd. of Regents of Univ. of the State of N.Y., 269 F. Supp. 339 (S.D.N.Y. 1967)