This note analyzes the Zobel II opinion and concludes that it was correctly decided both under the two-tier analysis employed by the United States Supreme Court and the balancing approach adopted by the Alaska court. Since this case is before the United States Supreme Court on appeal, this note urges the Court to adopt the Alaska balancing test for durational residence equal protection cases as a replacement for the traditional two-tier analysis.
E. T. Lewis,
Constitutional Law—Balancing Test in Durational Residence Equal Protection Analysis—Williams v. Zobel, 619 P.2d 448 (Alaska 1980), prob. juris. noted, 101 S. Ct. 1344 (1981),
56 Wash. L. Rev.
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