Bradwell v. State

83 U.S. 130 (1873) · Supreme Court of the United States · April 15, 1873

Summary

The Supreme Court of the United States ruled in Bradwell v. State that a state has the right to exclude a woman from practicing law in its courts. The court held that the right to practice law is not a privilege or immunity of citizenship under the Fourteenth Amendment. The decision was based on the idea that the right to control and regulate the granting of licenses to practice law is a power reserved to the states.

Court
Supreme Court of the United States
Writing for the Court
Justice Miller; Chief Justice; Justice Bradley; Justice Field; Justice Swayne
Jurisdiction
Federal
Decision date
April 15, 1873
Procedural posture
Writ of error to the Supreme Court of Illinois after that court denied Bradwell a license to practice law.
Standard of review
Review on writ of error of whether the state court's denial of admission to the bar violated the federal Constitution.
Precedential value
Published United States Supreme Court decision
Parties
Myra Bradwell v. The State of Illinois
Disposition
affirmed

Topics

constitutional lawprivileges or immunities clauseprivileges and immunitiesfourteenth amendmentcivil procedure

Practice areas

constitutional lawlegal profession and bar admissioncivil procedure

Questions Presented

  1. Whether Article IV, Section 2's Privileges and Immunities Clause protected Bradwell, as an Illinois resident and citizen, from Illinois's denial of a law license.
  2. Whether admission to practice law in a state court is a privilege or immunity of United States citizenship protected by the Fourteenth Amendment.

Holdings

  1. Article IV, Section 2 does not protect a citizen from the laws of the state of which she is a citizen; because Bradwell resided in Illinois, the Clause did not provide a basis for challenging Illinois's action.
  2. The right to admission to practice in the courts of a state is not a privilege or immunity of United States citizenship protected by the Fourteenth Amendment.

Key quotations

But the right to admission to practice in the courts of a State is not one of them. (139)
It is sufficient to say they are conclusive of the present case. JUDGMENT AFFIRMED. (139)

Factual background

Myra Bradwell, a resident of Chicago, Illinois, applied to the Illinois Supreme Court for a license to practice law after presenting evidence of good character and legal qualifications. She asserted that her citizenship and prior citizenship in Vermont entitled her to admission under Article IV, Section 2, and the Fourteenth Amendment. Illinois denied the application, relying on the common-law rule and its view that women were not eligible for admission to the bar.

Procedural history

Bradwell applied to the Supreme Court of Illinois for a license to practice law. The Illinois court denied the application, concluding that women were not eligible for admission under the applicable common-law and statutory framework. The United States Supreme Court affirmed.

Court Document

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