This article presents a review and analysis of selected state laws and initiatives that have attempted to restrict public school access for undocumented immigrant children in the wake of the landmark U.S. Supreme Court decision of "Plyler v. Doe." Sutton and Stewart begin with an overview of the Court's ruling in "Plyler," then they follow with examples of state-based challenges to "Plyler" in California and Alabama, where the former began as a ballot initiative and the latter as a legislative bill. Subsequently, both laws were successfully challenged in the courts. Discussions and conclusions are provided.