Also known as:rational relations · rational relationship · rational relationships · rational basis · rational basis test · rational basis review
Written by attorneys — see sources below.
A constitutional standard of review that upholds governmental action when the means chosen bear a minimally rational connection to a legitimate state objective. The test presumes validity unless the classification or regulation is wholly arbitrary or irrational.
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How its tested
Common Examples
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Visa Restriction Upheld
The President issues an order halting visas for construction workers from several majority-Muslim nations after intelligence reports flag sabotage risks to ports and military facilities. Alpha Framing, a contractor affected by the order, sues claiming religious animus. The court applies rational relation review and sustains the order because its stated national-security purpose supplies a legitimate objective and the temporary entry limits are rationally connected to preventing infiltration.
Bankruptcy Filing Reviewed
Ravi Reddy files for bankruptcy to discharge student loans while applying for bar admission. The character-and-fitness committee cites the filing as evidence of financial irresponsibility. The court upholds the inquiry because bar authorities may examine a wide range of conduct, including prior bankruptcy, so long as the questions remain rationally related to fitness to practice law.
A state enacts a statute banning most abortions. Rosalind Reed, a physician, challenges the law on due-process grounds. The court notes that even under rational-relation review a statute prohibiting abortion when the mother's life is at stake would lack any rational connection to a valid state objective and therefore could not stand.
Roe v. Wade410 U.S. 113 (1973)
In March 1970, Jane Roe, a single woman residing in Dallas County, Texas, instituted a federal action against the District Attorney of the county. She sought a declaratory judgment that the Texas criminal abortion statutes were unconstitutional on their face. She also sought an injunction restraining enforcement of the statutes.
Roe alleged that she was unmarried and pregnant. She wished to terminate her pregnancy by an abortion performed by a competent licensed physician under safe clinical conditions. She was unable to obtain a legal abortion in Texas because her life did not appear to be threatened by continuation of the pregnancy. She could not afford to travel to another jurisdiction to secure a legal abortion.
James Hubert Hallford, a licensed physician, sought and was granted leave to intervene in Roe's action. In his complaint he alleged that he had been arrested previously for violations of the Texas abortion statutes. Two such prosecutions were pending against him in the Criminal District Court of Dallas County. He described conditions of patients who came to him seeking abortions. He claimed that for many cases he was unable to determine whether they fell within or outside the exception recognized by Article 1196 of the Texas Penal Code.
John and Mary Doe, a married couple, filed a companion complaint also naming the District Attorney as defendant. The Does alleged that they were a childless couple. Mrs. Doe was suffering from a neural-chemical disorder. Her physician had advised her to avoid pregnancy until her condition materially improved. She had discontinued use of birth control pills pursuant to medical advice. If she should become pregnant she would want to terminate the pregnancy by an abortion performed by a competent licensed physician under safe clinical conditions.
The two actions were consolidated and heard together by a duly convened three-judge district court for the Northern District of Texas. Upon the filing of affidavits, motions were made for dismissal and for summary judgment. The court held that Roe and members of her class and Dr. Hallford had standing to sue and presented justiciable controversies. The Does had failed to allege facts sufficient to state a present controversy and did not have standing. It concluded that the Texas criminal abortion statutes were void on their face. The court dismissed the Does' complaint while denying injunctive relief.
The plaintiffs Roe and Doe and the intervenor Hallford appealed to the Supreme Court from that part of the District Court's judgment denying the injunction. The defendant District Attorney cross-appealed from the grant of declaratory relief. Both sides also took protective appeals to the United States Court of Appeals for the Fifth Circuit. That court ordered the appeals held in abeyance pending decision by the Supreme Court.
A state criminalizes the use of contraceptives by married couples. Riley Rivera and her spouse are prosecuted under the statute. The court observes that where a fundamental personal liberty is at stake the state may not prevail merely by showing some rational relation to a proper purpose. A compelling interest must be demonstrated instead.
Griswold v. Connecticut381 U.S. 479 (1965)
Estelle Griswold served as Executive Director of the Planned Parenthood League of Connecticut. Dr. C. Lee Buxton served as the League's Medical Director and was a professor at Yale Medical School. Together they opened and operated a center in New Haven that was open from November 1 to November 10, 1961.
At the center they gave information, instruction, and medical advice to married persons as to the means of preventing conception. They examined the wife and prescribed the best contraceptive device or material for her use. Fees were usually charged, although some couples were serviced free.
The statutes involved were sections 53-32 and 54-196 of the General Statutes of Connecticut (1958 rev.). Section 53-32 made it a crime to use any drug, medicinal article or instrument for the purpose of preventing conception. Section 54-196 punished accessories as principals. The appellants were found guilty as accessories and fined $100 each.
The Appellate Division of the Circuit Court affirmed the convictions. The Supreme Court of Errors of Connecticut affirmed that judgment in State v. Griswold, 151 Conn. 544, 200 A. 2d 479. The United States Supreme Court noted probable jurisdiction.
The appellants asserted standing to raise the constitutional rights of the married persons with whom they had a professional relationship. A criminal conviction for serving married couples removes doubts about case or controversy. The rights of husband and wife would be diluted unless considered in a suit involving those who have this kind of confidential relation to them.
A city zoning code limits occupancy of single-family homes to the head of household plus one dependent child. Rebecca Ross, who lives with her two grandsons, is cited for violating the ordinance. The court sustains the rule because the classification is rationally related to the legitimate objective of preserving the character of single-family neighborhoods.
Moore v. City of East Cleveland, Ohio431 U.S. 494, 503 (1977)
In early 1973, Mrs. Inez Moore received a notice of violation from the city of East Cleveland. The notice stated that her grandson John Moore, Jr., was an illegal occupant of her home. It directed her to comply with the housing ordinance.
Mrs. Moore lived in her East Cleveland home together with her son Dale Moore, Sr., and her two grandsons Dale Moore, Jr., and John Moore, Jr. John came to live with her after his mother's death when he was less than one year old. When she failed to remove John from the home, the city filed a criminal charge against her.
Mrs. Moore moved to dismiss the charge. She claimed that the ordinance was constitutionally invalid on its face. Her motion was overruled. Upon conviction she was sentenced to five days in jail and a $25 fine.
The East Cleveland ordinance limited occupancy of a dwelling unit to members of a single family. The ordinance defined family to include only a husband or wife of the nominal head of the household, unmarried children of the head or spouse provided they have no children residing with them, a parent of the head or spouse, or not more than one dependent child of the head or spouse along with that child's spouse and dependent children.
The Ohio Court of Appeals affirmed the conviction after giving full consideration to her constitutional claims. The Ohio Supreme Court denied review of the case. The United States Supreme Court noted probable jurisdiction of her appeal.
A state statute bars illegitimate children from inheriting from their fathers by intestacy. Raymond Ramos, an illegitimate child, is denied a share of his father's estate. The court holds that the classification must bear at least a rational relation to a legitimate state purpose and strikes down the statute because the distinction rests on an impermissible generalization about illegitimate children.
Trimble v. Gordon430 U.S. 762, 775 n.16 (1977)
Deta Mona Trimble is the illegitimate daughter of Jessie Trimble and Sherman Gordon. Trimble and Gordon lived together in Chicago with Deta Mona from 1970 until Gordon died in 1974 as the victim of a homicide. On January 2, 1973, the Circuit Court of Cook County, Illinois, entered a paternity order finding Gordon to be the father of Deta Mona and ordering him to pay fifteen dollars per week for her support. Gordon thereafter supported Deta Mona in accordance with the paternity order and openly acknowledged her as his child.
Gordon died intestate at the age of twenty-eight, leaving an estate consisting only of a 1974 Plymouth automobile worth approximately twenty-five hundred dollars. Shortly after Gordon's death, Trimble, as the mother and next friend of Deta Mona, filed a petition for letters of administration, determination of heirship, and declaratory relief in the Probate Division of the Circuit Court of Cook County. That court entered an order determining heirship, identifying as the only heirs of Gordon his father Joseph Gordon, his mother Ethel King, and his brother, two sisters, and a half brother. The Circuit Court excluded Deta Mona on the authority of section twelve of the Illinois Probate Act.
The Illinois Supreme Court affirmed the decision of the Circuit Court on the authority of its earlier decision in In re Estate of Karas. The United States Supreme Court noted probable jurisdiction to consider the arguments that section twelve violates the Equal Protection Clause of the Fourteenth Amendment by invidiously discriminating on the basis of illegitimacy and sex.
What two elements must a law satisfy under rational-relation review?
The government must pursue a legitimate objective, and the means chosen must bear a minimally rational connection to that objective. Only wholly arbitrary or irrational action fails the test.
Does rational-relation review allow a court to second-guess the legislature's actual motives?
No. Courts accept any conceivable legitimate purpose that the classification might rationally advance, even if the legislature never articulated it.
Supporting sources
When does a classification fail rational-relation review?
A classification fails only when it is wholly arbitrary or irrational and bears no rational connection to any legitimate governmental interest.
410 U.S. 113 (1973)
…test traditionally applied in the area of social and economic legislation is whether or not a law such as that challenged has a rational relation to a valid state objective. Williamson v. Lee Optical Co. , 348 U. S. 483, 491 (1955). The Due Process Clause of the Fourteenth Amendment undoubtedly does place a limit, albeit a broad…