487 U.S. 59 (1988)
Supreme Court of Virginia v. Friedman is a landmark Privileges and Immunities Clause decision addressing state-imposed residency requirements for the practice of law.
Does Virginia's requirement that only state residents may obtain bar admission on motion (without examination) violate the Privileges and Immunities Clause of Article IV, Section 2, by discriminating against nonresident attorneys in their pursuit of a common calling?
Under the Privileges and Immunities Clause of Article IV, Section 2, a state may not discriminate against citizens of other states with respect to fundamental rights—such as the pursuit of a common calling—unless (1) the state has a substantial reason for the differential treatment, and (2) the discriminatory means bear a close or substantial relationship to that reason. The state must show that nonresidents are a peculiar source of the evil the state seeks to remedy and that less restrictive, non-discriminatory alternatives would be inadequate. The practice of law is a protected privilege under this Clause.
Yes. Virginia's residency requirement for admission on motion violates the Privileges and Immunities Clause because it discriminates against nonresidents in their pursuit of the practice of law without a substantial reason closely related to that discrimination. The judgment invalidating the requirement was affirmed.
Friedman extends Piper's protection of nonresident lawyers to the context of admission on motion, confirming that states cannot impose residency requirements on any principal route to bar membership. The case crystallizes the Privileges and Immunities framework: when a state law discriminates against nonresidents in a protected economic activity, the state must justify that discrimination with substantial reasons and a close fit, and it must consider less discriminatory alternatives. For law students, Friedman is a key precedent in occupational licensing challenges and a template for analyzing Art. IV, § 2 issues alongside cases like Toomer, Hicklin, and Camden.