In the case of Nyquist, Commissioner of Education of New York, et al. v. Mauclet et al., 1976, the U.S Supreme Court ruled that a New York law was unconstitutional because it discriminated against lawful resident aliens based on their alienage. The law in question denied state financial aid to residents who were not U.S citizens or did not intend to become one unless they had applied for citizenship as soon as they were eligible to do so. Jean Mauclet and two other legal permanent residents challenged this statute after being denied aid due to their decision not to apply for citizenship despite being eligible. The court held that such discrimination could only be justified if it served a substantial state interest related directly with the particular classification involved; however, no such interest was found in this case.

In the dissenting opinion for NYQUIST, COMMISSIONER OF EDUCATION OF NEW YORK, et al. v. MAUCLET et al., 1976, Justice Rehnquist argued that the majority's decision was inconsistent with previous rulings on similar issues and failed to properly consider state interests in controlling public funds. He contended that New York State had a legitimate interest in limiting financial aid to students who were not only legally present but also intended to become permanent residents of the United States. The statute did not discriminate based on race or nationality as it applied equally to all noncitizens regardless of their country of origin. Furthermore, he pointed out that Congress had given states broad discretion over educational policy and funding decisions under Title IV of the Higher Education Act; therefore, this law should be considered presumptively valid unless proven otherwise by compelling evidence.