Supreme Court of Virginia v. Friedman

Myrna Friedman (plaintiff) was admitted to the Illinois bar and District of Columbia bar. Friedman worked for several years as an attorney for the Navy in Virginia and for several years after that in private practice in Washington, D.C. In 1986, she began working as an in-house attorney for a company in Virginia. In February 1986, Friedman married and moved from Virginia to Maryland but did not change jobs. In June 1986, Friedman applied for admission to the Virginia bar by motion. Under the rules established by the Virginia Supreme Court (defendant), only attorneys who are permanent citizens of Virginia were permitted to be admitted to the bar on motion. The rules also required that attorneys admitted by motion maintain an office for the practice of law in Virginia. Nonresident attorneys were required to take the bar examination, even if they met all the other requirements. Friedman’s motion for admission explained that she was practicing law full-time in Virginia, would be available for service of process in Virginia, and that she would keep informed of the local rules. However, the Virginia Supreme Court denied her motion for admission because she was not a permanent resident of Virginia. Friedman sued, alleging that the residency requirement violated the Privileges and Immunities Clause of the United States Constitution.