Alienage, or the state of being an alien, i.e. a non-citizen of the United States, is a unique category. For purposes of state law, legal aliens are a suspect class ("Graham v. Richardson", 403 U.S. 365 (1971)). As such, state actions are analyzed according to strict scrutiny. In contrast, because the United States Congress has the power to regulate immigration, federal government action that discriminates based on alienage will receive rational basis scrutiny. State acts that affect unlawful immigrants are generally analyzed with rational basis review unless the topic is education of children, in which case they are analyzed under intermediate scrutiny based on "Plyler v. Doe", 457 U.S. 202 (1982).