This paper explores some of the implications of Justice William O. Douglas's dissenting opinion in "DeFunis v. Odeggard" for the selection, education, and licensing of educational personnel. Douglas's argument for "cultural neutrality" in law-education selection instruments turns on his argument for racially neutral tests. That is, Douglas's argument appears to say that public institutions have a particular responsibility to make certain that they conduct their affairs on a culturally neutral basis where racial minorities are involved. With respect to the selection of students into teacher education programs, Douglas's opinion, if adopted by the full Court, would require substantial revision in institutional practices. Presently, college grades, English proficiency, and academic references are among the most commonly used criteria for selection of students. These appear not to meet the tests for adequacy that Douglas suggests in his opinion. While selection is an important phase in the training of teachers, Douglas's arguments are even more important with regard to certification or licensing. According to Freeman, Douglas's argument, when considered in the field of teacher education, would seem to make the use of such standardized and heavily relied upon examinations as the National Teacher Examination inappropriate. (JA)