Also known as: rational relationships · rational relation · rational relations · rational basis · rational basis review · rational basis test
Written by attorneys — see sources below.
A standard of judicial review under which a law or classification is upheld if it bears a reasonable connection to a legitimate governmental interest. Courts apply this deferential test when no fundamental right or suspect classification is involved. The inquiry assumes the existence of facts supporting the legislative judgment and permits underinclusive or overinclusive measures.
President issues an order barring entry by construction workers from several majority-Muslim nations after intelligence reports flag sabotage risks at ports in State A. Raphael Rivera, a foreign architect, sues claiming religious animus. The court finds the order states a national-security purpose and the entry limits are rationally related to that purpose, so the challenge fails.
Ryan Roberts files for bankruptcy to discharge student loans before applying to the state bar. The character committee cites the filing as evidence of irresponsibility. The court upholds the denial because the inquiry into financial conduct bears a rational relationship to fitness to practice law.
Roland Rhodes lives with his son and two grandsons who are cousins. City of East Cleveland enforces an ordinance limiting occupancy to nuclear families. The court strikes the ordinance because the distinction among blood relatives lacks a rational relationship to density or traffic control.
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.
View caseRita Russell, a married woman, seeks contraceptives from a licensed physician. State law criminalizes their use and distribution. The court applies heightened scrutiny because the statute burdens a fundamental liberty and cannot be sustained by mere rational relationship to health or morals.
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.
View caseRavi Reddy, an illegitimate child, is barred from inheriting from his father under state intestacy law. The statute presumes only legitimate children inherit. The court holds the classification fails even rational-basis review because it bears no rational relationship to encouraging legitimate family formation.
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.
View caseRoyal Crest Hotels owns land zoned for single-family residences. The village of Euclid prohibits apartment buildings. The court upholds the ordinance because separating residential uses bears a rational relationship to public health, safety, and general welfare.
The Village of Euclid is an Ohio municipal corporation that adjoins and is practically a suburb of the City of Cleveland. Its estimated population is between 5,000 and 10,000, and its area spans from twelve to fourteen square miles, with the greater part consisting of farm lands or unimproved acreage. It lies roughly in the form of a parallelogram measuring approximately three and one-half miles each way and is traversed east and west by three principal highways and two railroads. Ambler Realty Co. owns a tract of land containing 68 acres situated in the westerly end of the village. This tract abuts on Euclid Avenue to the south and the Nickel Plate railroad to the north. Adjoining this tract on both the east and the west, restricted residential plats have been laid out upon which residences have been erected. On November 13, 1922, the Village Council adopted an ordinance establishing a comprehensive zoning plan. The ordinance divides the village into six use districts denominated U-1 to U-6, three height districts denominated H-1 to H-3, and four area districts denominated A-1 to A-4. Appellee's tract is classified as U-2 for the first 620 feet north of Euclid Avenue, U-3 for the next 130 feet, and U-6 for the remainder. Enforcement of the ordinance is entrusted to the inspector of buildings under rules and regulations of the board of zoning appeals. The board holds public meetings, keeps minutes of its proceedings, and possesses authority to interpret the ordinance in cases of practical difficulty or unnecessary hardship, while penalties are prescribed for violations. Ambler Realty Co. filed suit alleging that the tract has been held for years for sale and development for industrial uses for which it is especially adapted. The bill further alleged that unrestricted market value is about $10,000 per acre but limited to residential purposes the value does not exceed $2,500 per acre, that the first 200 feet back from Euclid Avenue has a value of $150 per front foot if unrestricted but not in excess of $50 per front foot if limited to residential uses, and that the ordinance confiscates and destroys a great part of its value while deterring prospective buyers. The bill sought an injunction restraining enforcement of the ordinance. The district court overruled a motion to dismiss on the ground that the suit was premature. The district court held the ordinance unconstitutional and void and enjoined its enforcement.
View caseRational relationship review applies when a law neither burdens a fundamental right nor employs a suspect or quasi-suspect classification. Courts presume constitutionality and uphold the measure if any legitimate purpose exists and the classification is reasonably related to it.
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Yes. Under rational basis review a statute may be underinclusive or overinclusive so long as it is rationally related to a legitimate purpose. Courts defer to legislative judgments and do not require perfect fit.
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No. When the law states a legitimate purpose and is rationally related to it, courts apply deferential review even if stray statements suggest improper motive. The inquiry focuses on the text and the relationship to the stated goal.
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Congress may not use Section 5 to impose remedies that prohibit conduct valid under rational basis review. Any enforcement statute must be congruent and proportional to a documented pattern of unconstitutional state action.
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…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…