Fourth Circuit upholds North Carolina's comity admission requirements

In MORRISON v. BOARD OF LAW EXAMINERS, Morrison sought admission to the North Carolina bar under its comity rules and was denied admission. In North Carolina, if an applicant is duly licensed to practice law in a state having comity with North Carolina and has practiced in a state having comity for four out of the last six years, the applicant is eligible for admission. Morrison had not practiced four out of the last six years in a state with comity and thus was denied admission to the North Carolina bar. He challenged this denial on constitutional grounds. The district court granted summary judgment for Morrison, but the Fourth Circuit reversed. According to the panel:

However, the negative impact on Morrison does not render the rule invalid. North Carolina is not discriminating against citizens of other States in favor of her own. The rule simply represents North Carolina's "undertaking to secure for its citizens an advantage by offering that advantage to citizens of any other state on condition that the other state make a similar grant."