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In recent years, aliens' have made great strides against state-imposed employment discrimination. 2 Some commentators read recent Supreme Court opinions in Sugarman v. Dou gall3 and In re Griffiths4 as invalidating virtually all state laws that require United States citizenship as a prerequisite to employment. 5 Nonetheless, many states still bar aliens from teaching in public elementary and secondary schools. This Note analyzes the constitutionality of state-imposed restrictions on the employment of alien teachers. It argues that Sugarman and Griffiths, while greatly limiting the scope of permissible discrimination against aliens, recognize an excepted area for jobs which have a critical relationship to the identity and legitimacy of the political community. Public school teaching might fit within this area of allow-

Aliens' Right to Teach: Political Socialization and the Public Schools