In the case of Toll, President, University of Maryland et al. v. Moreno et al., 1981, the U.S Supreme Court ruled in favor of a group of non-resident alien students who were denied in-state tuition rates at the University of Maryland due to their immigration status. The court held that this policy violated the Equal Protection Clause under Fourteenth Amendment as it discriminated against these individuals based on their legal residency status without any substantial state interest justifying such discrimination. The university's argument that offering lower tuition to residents was intended to serve state’s legitimate interests did not hold up because these students were legally residing within Maryland and contributing towards its economy despite being non-immigrants according to federal law.

In the dissenting opinion for Toll, President, University of Maryland v. Moreno et al., Justice Rehnquist disagreed with the majority's interpretation of a federal statute that allowed states to deny in-state tuition benefits to non-immigrant aliens. He argued that Congress had not intended to prevent states from making such distinctions when it passed this legislation. Instead, he believed that Congress was primarily concerned with preventing illegal immigration and did not intend to interfere with state policies regarding legal immigrants. Furthermore, he contended that even if Congress had wanted to protect certain categories of legal immigrants from discrimination by states, it would have done so explicitly rather than implicitly as the majority suggested. Therefore, according to Justice Rehnquist’s view on statutory interpretation and legislative intent analysis principles applied in this case were incorrect.