Also known as: rational basis standard · rational basis test · rational basis review · rational basis scrutiny · rational basis
Written by attorneys — see sources below.
A deferential standard of judicial review under which a classification or regulation is upheld if it is rationally related to a legitimate governmental interest.
The President issues an order barring pilots from several majority-Muslim countries after intelligence reports flag hijacking risks. Angelica, a foreign trainee denied entry, sues claiming religious animus. The court applies rational basis review and sustains the order because its stated national security purpose bears a rational relationship to the entry limits.
A state requires transit authorities to pay minimum wages to employees. The authority challenges the mandate as exceeding federal commerce power. The court applies rational basis review and upholds the requirement because Congress could rationally conclude that wage rules affect interstate commerce.
The history of public transportation in San Antonio began with private operators. In 1959 the City of San Antonio purchased the privately owned San Antonio Transit Company and replaced it with the publicly owned San Antonio Transit System. In 1978 the city transferred its facilities and equipment to appellee San Antonio Metropolitan Transit Authority, a public mass-transit authority organized on a countywide basis. SAMTA became the major provider of transportation in the San Antonio metropolitan area. Between 1978 and 1980 its vehicles traveled over 26 million route miles and carried over 63 million passengers. San Antonio began receiving federal subsidies under the Urban Mass Transportation Act of 1964. SATS and SAMTA received over $51 million in UMTA grants from December 1970 through February 1980. This total included $12.5 million in operating grants during SAMTA's first two fiscal years. The Fair Labor Standards Act was enacted in 1938 without applying to local mass-transit employees. Congress amended the statute in 1961 to extend minimum-wage coverage to private mass-transit carriers with annual gross revenue of at least $1 million. In 1966 Congress withdrew exemptions from public hospitals, schools, and mass-transit carriers whose rates and services were subject to state regulation. The 1974 amendments provided for the progressive repeal of the surviving overtime exemption for mass-transit employees while extending FLSA coverage to virtually all state and local government employees. Following the 1976 decision in National League of Cities v. Usery, SATS informed its employees that the decision relieved it of overtime obligations under the FLSA. On September 17, 1979, the Wage and Hour Administration of the Department of Labor issued an opinion that SAMTA's operations were not constitutionally immune from the FLSA. On November 21, 1979, SAMTA filed suit against the Secretary of Labor in the United States District Court for the Western District of Texas seeking declaratory relief. On the same day appellant Garcia and other SAMTA employees sued SAMTA in the same court for overtime pay under the FLSA. On November 17, 1981, the District Court granted SAMTA's motion for summary judgment. The court held that local public mass-transit systems constitute integral operations in areas of traditional governmental functions. After the Supreme Court decided Transportation Union v. Long Island R. Co. in 1982, the District Court's judgment was vacated and remanded. On remand the District Court adhered to its original view and again entered judgment for SAMTA in 1983. The Secretary and Garcia took direct appeals. The Supreme Court noted probable jurisdiction, restored the cases for reargument after initial argument, and requested briefing on whether the principles of the Tenth Amendment as set forth in National League of Cities v. Usery should be reconsidered.
View caseA city denies a permit for a group home serving adults with intellectual disabilities, citing safety concerns near a flood plain. The operator sues under equal protection. The court applies rational basis review and upholds the denial because the zoning decision is rationally related to legitimate public safety interests.
In July 1980, respondent Jan Hannah purchased a building at 201 Featherston Street in Cleburne, Texas. Hannah intended to lease the property to Cleburne Living Center, Inc. (CLC) for use as a group home. The home would house thirteen mentally retarded men and women under constant staff supervision. The building contained four bedrooms and two baths, and CLC planned to add a half bath while complying with all applicable state and federal regulations for an Intermediate Care Facility for the Mentally Retarded. The site lay in an R-3 Apartment House District. The city's zoning ordinance permitted apartment houses, boarding houses, hospitals, and nursing homes in that district without special permission. However, the ordinance required a special use permit, renewable annually after a public hearing, for hospitals for the insane or feeble-minded. The city classified the proposed group home as a hospital for the feeble-minded and informed CLC that a permit was required. After a public hearing, the City Council voted three to one to deny the application. CLC and its prospective residents filed suit in federal district court against the city and its officials. They alleged that the ordinance and its application discriminated against the mentally retarded in violation of the Equal Protection Clause. The district court upheld the ordinance and the denial. It found that the council's decision was motivated by the residents' mental retardation yet rationally related to legitimate interests such as neighborhood safety and property values. The Court of Appeals for the Fifth Circuit reversed, holding that mental retardation is a quasi-suspect class and that the ordinance was invalid both facially and as applied. The Supreme Court granted certiorari to review the equal protection issues raised by the zoning ordinance and its application to the proposed group home.
View caseCongress creates a federal cause of action for gender-motivated violence. A victim sues her attacker in federal court. The court applies rational basis review to the commerce justification and holds that the statute exceeds Congress's power because the regulated conduct lacks a sufficient rational connection to interstate commerce.
In September 1994 Christy Brzonkala enrolled as a student at Virginia Polytechnic Institute and State University. Within thirty minutes of meeting fellow students Antonio Morrison and James Crawford, both members of the varsity football team, Brzonkala alleges that the two men assaulted and repeatedly raped her. Morrison allegedly told Brzonkala after the attack that she had better not have any diseases. He later announced in a dormitory dining room that he liked to get girls drunk and made other vulgar remarks about women. Brzonkala became severely emotionally disturbed and depressed after the incident. She sought assistance from a university psychiatrist who prescribed antidepressant medication. She stopped attending classes and withdrew from the university. In early 1995 she filed a complaint against Morrison and Crawford under the university's Sexual Assault Policy. Virginia Tech conducted a hearing under its Sexual Assault Policy and a second hearing under its Abusive Conduct Policy. The first found Morrison guilty of sexual assault and suspended him for two semesters. The second hearing again found him guilty but changed the offense description to using abusive language. University officials later set aside the punishment. In December 1995 Brzonkala sued Morrison, Crawford, and Virginia Tech in the United States District Court for the Western District of Virginia. Her complaint alleged that the attack violated 42 U.S.C. §13981, the civil remedy provision of the Violence Against Women Act of 1994, which creates a federal cause of action for compensatory and punitive damages against persons who commit crimes of violence motivated by gender. She also asserted Title IX claims against the university. The district court dismissed the Title IX claims for failure to state a claim. It also dismissed the §13981 claim on the ground that Congress lacked authority to enact the provision under either the Commerce Clause or Section 5 of the Fourteenth Amendment. A divided panel of the Fourth Circuit reversed in part, but the en banc Fourth Circuit affirmed the district court's conclusion that Congress lacked constitutional authority to enact §13981. The Supreme Court granted certiorari to determine the constitutionality of the civil remedy provision.
View caseCongress bans interstate shipment of filled milk products. A manufacturer challenges the prohibition as arbitrary. The court applies rational basis review and sustains the ban because Congress could rationally conclude that the products pose health risks warranting regulation.
In March 1923, Congress enacted the Filled Milk Act. The statute prohibits the shipment in interstate commerce of skimmed milk compounded with any fat or oil other than milk fat so as to resemble milk or cream. Carolene Products Company was indicted for the shipment in interstate commerce of packages of Milnut. Milnut is a compound of condensed skimmed milk and coconut oil made in imitation or semblance of condensed milk or cream. The United States indicted Carolene Products in the district court for the southern district of Illinois for violation of the Act by the shipment in interstate commerce of packages of Milnut. The indictment stated in the words of the statute that Milnut is an adulterated article of food injurious to the public health. It further stated that Milnut is not a prepared food product of the type excepted from the prohibition of the Act. The trial court sustained a demurrer to the indictment on the authority of an earlier case in the same court. The case was brought to the Supreme Court on appeal under the Criminal Appeals Act of March 2, 1907. The Court of Appeals for the Seventh Circuit has meanwhile upheld the Filled Milk Act as an appropriate exercise of the commerce power in a separate case. Prior to passage of the Act, Congress held committee hearings. Eminent scientists and health experts testified during those hearings. An extensive investigation was made of the commerce in milk compounds in which vegetable oils have been substituted for natural milk fat. The investigation also examined the effect upon the public health of the use of such compounds as a food substitute for milk. The conclusions drawn from evidence presented at the hearings were embodied in reports of the House Committee on Agriculture and the Senate Committee on Agriculture and Forestry. Carolene Products assailed the statute as beyond the power of Congress over interstate commerce. It also complained that the statute denies equal protection of the laws and deprives it of its property without due process of law in violation of the Fifth Amendment. The challenge focused particularly on the statute's purportedly binding and conclusive legislative declaration that the product is an adulterated article of food injurious to the public health.
View caseA police department adopts a grooming policy requiring officers to maintain neat hairstyles. An officer challenges the rule as violating due process. The court applies rational basis review and sustains the policy because it is reasonably related to the legitimate interests of discipline and uniformity.
Petitioner Florence Dolan owns a plumbing and electric supply store located on a 1.67-acre parcel of land in the business district of the city of Tigard, Oregon. The store is on a parcel that includes a 9,700-square-foot building, and Fanno Creek flows through the southwestern corner of the lot within the 100-year floodplain. In the early 1970's, the city developed a comprehensive plan for managing surface water drainage in the Fanno Basin serving the area where the property is located. The comprehensive plan also contained provisions for a pedestrian and bicycle pathway system throughout the city, one of which was to follow along Fanno Creek. In 1988, petitioner applied for a permit to expand her store and pave the parking lot. The city planning commission granted the permit but required petitioner to dedicate a portion of her property for the construction of a public greenway along Fanno Creek and an additional 15-foot strip of land adjacent to the greenway for a pedestrian and bicycle pathway. The dedication required encompasses approximately 7,000 square feet, or roughly 10% of the property. Petitioner requested a variance from the city's dedication requirements. The planning commission denied the variance, and the city council affirmed the denial. Petitioner then filed suit in Oregon state court claiming an uncompensated taking. The Oregon trial court upheld the city's requirements. The Oregon Court of Appeals affirmed, as did the Oregon Supreme Court. The United States Supreme Court granted certiorari. The question presented was what standard of review applies to a claim that a city's exaction of a dedication of private property as a condition of a building permit constitutes an uncompensated taking of property in violation of the Fifth Amendment.
View caseRational basis review applies to classifications that do not involve suspect classes or fundamental rights. Courts use it for most economic and social legislation, including federal alienage distinctions and age or disability classifications.
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The court asks only whether the classification is rationally related to a legitimate governmental interest. Underinclusiveness or overinclusiveness does not defeat the law so long as some rational connection exists.
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No. When the measure itself states a legitimate purpose that is rationally advanced by its terms, stray statements suggesting bias do not invalidate it under this standard.
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Congress may not rely on rational basis review alone. Its Section 5 remedies must be congruent and proportional to a documented pattern of unconstitutional state conduct. Otherwise the legislation exceeds its enforcement power.
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Courts give substantial deference. A law passes if any reasonably conceivable set of facts supports the classification, even if the fit between means and ends is imperfect.
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…v. Cleburne Living Center, Inc. , 473 U. S. 432, 439 (1985); see also Plyler v. Doe , 457 U. S. 202, 216 (1982). Under our rational basis standard of review, "legislation is presumed to be valid and will be sustained if the classification drawn by the statute is rationally related to a legitimate state interest." Cleburne v. Cleburne…