In Hodges, the first case in which we interpreted section 3333.4, we found that the language of section 3333.4, specifically the phrase "any action to recover damages arising out of the operation or use of a motor vehicle," was "not pellucid."
In Sei Fujii v. State of California, 38 Cal.2d 718, 730-731 [ 242 P.2d 617], the Supreme Court of this state, recognizing that the latest declarations of the United States Supreme Court on the California Alien Land Law were irreconcilable with the approach previously taken in a case which had not been overruled (and in which, unlike the Drueding case, there had been a full-fledged opinion), followed the more recent decisions.
In Raffaelli, the California Supreme Court struck down a California statute excluding aliens from admission to the State Bar. The plaintiff in Raffaelli was an Italian citizen who went to law school in California and passed the California bar exam, but was nevertheless refused admission to the State Bar because he was a citizen of Italy. Employing strict scrutiny analysis because alienage is a suspect class, the Court found that there was no compelling reason to deny aliens admission to the bar.