## Facts

- Fifteen Iranian citizens were students at a state university and were in lawful immigration status and academic good standing.
- During the Iran hostage crisis, the university’s board of regents adopted a policy denying “subsequent enrollment” to any student whose home government held or permitted U.S. hostages.
- By stipulation, Iran was the only country fitting the policy’s terms at the time, so the policy operated only against Iranian students.
- The students sought declaratory and injunctive relief (no damages), alleging violations of equal protection and due process, unlawful national-origin discrimination under Title VI, and invalidity under the Supremacy Clause because the policy intruded into immigration and foreign affairs.
- A preliminary injunction temporarily barred enforcement pending a decision on the merits.

## Issues

1. Whether a state university’s exclusion of students based on alienage and national origin (as applied to Iranian students) violates the Equal Protection Clause.
2. Whether denying continued enrollment to lawfully present, academically qualified students without individualized grounds violates procedural due process.
3. Whether a state university policy aimed at affecting a foreign-policy dispute is preempted because it intrudes into federal authority over immigration and foreign relations.
4. Whether the policy constitutes prohibited national-origin discrimination in a federally funded education program under Title VI.

## Decision

- The court declared the regents’ enrollment policy unconstitutional and permanently enjoined the university, the board, and the regents from enforcing it against the plaintiffs.
- The court held the policy violated equal protection because it discriminated against Iranian students on suspect grounds without a constitutionally sufficient justification.
- The court also held the policy was invalid under the Supremacy Clause because it functioned as a state-level response to an international crisis, intruding into federal immigration and foreign-affairs powers.
- The preliminary injunction was effectively made permanent through the final judgment.

## Legal Principles

- Classifications by a state actor based on alienage and national origin are suspect and are subject to strict scrutiny.
- Generalized political, financial, or community sentiment—untethered to individualized student conduct—does not constitute a compelling interest that can justify excluding an entire national group from public education.
- State institutions may not impose measures intended to influence or retaliate against foreign governments through restrictions on foreign nationals; such actions are preempted in areas committed to the federal government, including immigration regulation and foreign relations.
- Lawfully present students in good standing may not be denied continued enrollment on categorical grounds unrelated to academic performance or lawful status without constitutionally adequate process.

## Conclusion

The court permanently barred enforcement of a state university enrollment policy that functioned as a categorical exclusion of Iranian students, holding it unconstitutional under equal protection principles and preempted because it interfered with federal control over immigration and foreign affairs.


Tayyari v. New Mexico State Univ., 495 F. Supp. 1365 (D.N.M. 1980)