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Padilla v. Allison

Citations: 38 Cal. App. 3d 784; 113 Cal. Rptr. 582; 1974 Cal. App. LEXIS 1096Docket: Civ. 41657

Court: California Court of Appeal; April 24, 1974; California; State Appellate Court

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Appellants, permanent resident aliens in California, challenged the state's requirement of U.S. citizenship for voting, claiming it violated their equal protection rights under the Fourteenth Amendment. The trial court dismissed their complaint, ruling it failed to state a cause of action. On appeal, the key issue is whether the citizenship prerequisite for voting infringes upon rights guaranteed by the U.S. Constitution. The appellants argue they meet all other voter registration requirements, except for citizenship and the ability to speak, read, and write English. The court referenced the Supreme Court's position that aliens do not possess a constitutional right to vote under the Equal Protection Clause and noted that Congress holds the authority to set qualifications for nationality. It distinguished the rights of naturalized citizens from those of non-citizens, confirming that while California cannot deny voting rights to citizens based on language ability, it is not obligated to grant voting rights to non-citizens. The ruling emphasizes that the state's election laws reflect a legislative determination to allow only U.S. citizens to vote, thus upholding the citizenship requirement.

States are not obligated to extend voting rights to aliens, as established in Rodriguez. The Fourteenth Amendment does not require their enfranchisement, and federal naturalization prerequisites do not invalidate a state’s decision to deny voting rights to aliens. Aliens lack a constitutional right to citizenship and, by extension, to participate in the political process. The requirements for naturalization include lawful permanent residency for at least five years, good moral character, knowledge of U.S. history and government principles, absence of anarchist affiliations, and proficiency in English. Attempts to distinguish prior case law regarding the right to hold office from the right to vote are unconvincing, as both rights are fundamentally linked to political participation. While the U.S. Supreme Court has not definitively addressed the issue of alien voting rights, numerous state and federal opinions have consistently limited the franchise to citizens. Historically, some states permitted aliens to vote, but current constitutional interpretations affirm that naturalized citizens possess equal rights to native citizens, except for presidential eligibility.