Also known as: rational relationship test · rational relationship scrutiny · rational basis test · rational basis review · rational basis scrutiny
Written by attorneys — see sources below.
A standard of judicial review under which a classification or regulation is upheld if it is rationally related to a legitimate governmental interest. Courts apply heavy deference to legislative judgments and sustain laws even when they are underinclusive or overinclusive. The standard governs equal protection and due process challenges that do not involve suspect classifications or fundamental rights.
The state requires all police officers to retire at age fifty. Roger Ramirez, a fifty-one-year-old officer who passes every physical test, sues claiming the rule is arbitrary. The court upholds the statute because the age cutoff advances the legitimate goal of maintaining a physically capable force and need only be rationally related to that objective.
The President issues an order barring entry of pilots from several majority-Muslim countries after intelligence reports flag heightened hijacking risks. Rina Rahman, a foreign national denied training, challenges the order on Establishment Clause grounds. The court sustains the order because it states a national-security purpose and the restriction is rationally related to that purpose.
A state funds public schools primarily through local property taxes, producing large disparities between wealthy and poor districts. Roland Rhodes, a student in a low-wealth district, sues alleging equal protection violations. The court applies rational basis review and upholds the system because local control of education is a legitimate interest and the funding method is rationally related to that interest.
In the summer of 1968 Mexican-American parents whose children attended elementary and secondary schools in the Edgewood Independent School District in San Antonio Texas brought a class action. They sued on behalf of schoolchildren throughout the state who were members of minority groups or who were poor and resided in school districts having a low property tax base. Named as defendants were the State Board of Education the Commissioner of Education the State Attorney General and the Bexar County Board of Trustees. The complaint was filed in the United States District Court for the Western District of Texas. A three-judge court was impaneled in January 1969. The Texas system of financing public education originated with the state's first constitution in 1845. It evolved through constitutional amendments permitting local school districts to levy ad valorem taxes for school buildings and maintenance. These local revenues were supplemented by distributions from the state's Permanent School Fund established in 1854 and the Available School Fund. In the late 1940s the legislature enacted the Minimum Foundation School Program. Under the program the state supplies approximately 80 percent of the cost of teacher salaries operating expenses and transportation. Each district contributes the remaining 20 percent through a Local Fund Assignment. The assignment is calculated by an economic index reflecting relative taxpaying ability. Every district also levies additional local property taxes beyond the assignment to supplement its foundation grant. For the 1967-1968 school year the Edgewood Independent School District had an average assessed property value of $5960 per pupil and a median family income of $4686. It raised $26 per pupil through local taxation at a rate of $1.05 per $100 of assessed valuation. It received $222 per pupil from the Foundation Program and obtained $108 in federal funds for a total of $356 per pupil. By comparison the Alamo Heights Independent School District had an assessed property value exceeding $49000 per pupil and a median family income of $8001. It raised $333 per pupil locally at a rate of $0.85 per $100 received $225 from the Foundation Program and $36 in federal funds for a total of $594 per pupil. Similar disparities in per-pupil expenditures existed throughout the state. They were largely attributable to differences in the amount of taxable property within each district. In December 1971 the three-judge District Court rendered judgment holding the Texas school finance system unconstitutional under the Equal Protection Clause of the Fourteenth Amendment. The State appealed. The Supreme Court noted probable jurisdiction in 1972 to consider the constitutional questions presented.
A state imposes higher taxes on out-of-state insurance companies than on domestic insurers. Reliance Insurance, an out-of-state carrier, challenges the tax as irrational. The court upholds the statute because encouraging in-state insurance business is a legitimate purpose and the tax distinction is rationally related to that goal.
Since 1955 Alabama has maintained a domestic preference tax statute that taxes the gross premiums received by insurance companies on policies issued in the State. Foreign life insurance companies pay a tax at a rate of three percent, and foreign companies selling other types of insurance pay at a rate of four percent. All domestic insurance companies pay at a rate of only one percent. The statute permits domestic insurers to exclude from taxable premium income all premiums received from policies issued in other States in which they are not licensed. Foreign insurers may reduce but never eliminate the tax differential by investing prescribed percentages of their worldwide assets in specified Alabama assets and securities. Appellants are a group of insurance companies incorporated outside Alabama. Metropolitan Life Insurance Co. represents the life insurance claimants, and Prudential Property and Casualty Co. represents the nonlife claimants. In 1981 appellants filed claims with the Alabama Department of Insurance seeking refunds of taxes paid for the tax years 1977 through 1980. They contended that the domestic preference tax statute as applied to them violated the Equal Protection Clause. The Commissioner of Insurance denied all claims on July 8, 1981. Appellants appealed to the Circuit Court for Montgomery County. The court consolidated the appeals and selected two lead cases. On cross-motions for summary judgment the court ruled on May 17, 1982 that the statute was constitutional. After the Court of Civil Appeals affirmed the finding of legitimate state purposes but remanded for an evidentiary hearing on rational relationship, appellants waived their right to an evidentiary hearing. The Alabama Supreme Court ultimately entered judgment for the State and intervenors. The Supreme Court of the United States noted probable jurisdiction in 1984. It consolidated the cases and heard argument on October 31, 1984.
Congress creates a private damages action for victims of gender-motivated violence. Raphael Rivera, a defendant in such a suit, argues the statute exceeds federal power. The court strikes down the provision because gender-based violence lacks a sufficient connection to interstate commerce and the remedy fails even rational basis review in that context.
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.
Congress attempts to authorize private damages suits against states for age discrimination in employment. Rebecca Ross, a state employee denied recovery, challenges the statute's validity. The court holds that age classifications receive only rational basis review and that Congress lacked authority under Section Five to impose such liability on states.
In 1967 Congress enacted the Age Discrimination in Employment Act, which initially applied only to private employers. In 1974 Congress amended the Act through the Fair Labor Standards Amendments to extend its substantive requirements to the States. Congress redefined the term employer to include a State or political subdivision of a State and any agency or instrumentality of a State or a political subdivision of a State. The same legislation also amended the incorporated Fair Labor Standards Act enforcement provision to authorize suits against any employer including a public agency in federal or state court. In December 1994 Roderick MacPherson and Marvin Narz, associate professors ages 57 and 58 at the University of Montevallo in Alabama, filed suit alleging age discrimination, retaliation for filing charges with the Equal Employment Opportunity Commission, and disparate impact from an evaluation system. In April 1995 J. Daniel Kimel, Jr., and other current and former faculty and librarians over age 40 at Florida State University and Florida International University filed suit against the Florida Board of Regents alleging that the failure to allocate previously agreed market-adjustment salary funds had a disparate impact on employees with longer service records. In May 1996 Wellington Dickson filed suit against the Florida Department of Corrections alleging failure to promote him because of his age and in retaliation for grievances concerning age discrimination. The District Court in the MacPherson case granted the university's motion to dismiss on Eleventh Amendment grounds. The District Courts in the Kimel and Dickson cases denied the state defendants' motions to dismiss. The United States intervened in all three cases. The Court of Appeals for the Eleventh Circuit consolidated the appeals and held that the ADEA does not abrogate the States' Eleventh Amendment immunity. The Supreme Court granted certiorari to resolve a conflict among the Courts of Appeals.
The rational relationship standard applies to classifications that are neither suspect nor quasi-suspect and that do not burden fundamental rights. Age, disability, and most economic or social distinctions receive this deferential review. Federal alienage classifications in immigration and benefits contexts also receive at most rational basis review.
…the ground that "[t]he crafting and safeguarding of public morality . . . indisputably is a legitimate government interest under rational basis scrutiny"); Milner v. Apfel , 148 F. 3d 812, 814 (CA7 1998) (citing Bowers for the proposition that "[l]egislatures are permitted to legislate with regard to morality . . . rather than confined…
…turns on commercial character, the Court gestures toward two other considerations that it might sometime entertain in applying rational basis scrutiny (apart from a statutory obligation to supply independent proof of a jurisdictional element): does the congressional statute deal with subjects of traditional state regulation, and does the…
…and reach of its holding. Further, The Chief Justice admits that he would overrule the central holding of Roe and adopt the rational relationship test
…of unconstitutional grounds. Pp. 30–32. (d) On the few occasions where the Court has struck down a policy as illegitimate under rational basis scrutiny, a common thread has been that the laws at issue were “divorced from any factual context from which [the Court] could discern a
Courts give substantial deference and will uphold a law if any reasonably conceivable set of facts supports it. Laws may be underinclusive or overinclusive without failing the test. Administrative convenience and anti-fraud goals can justify classifications that are not perfectly tailored.
No. When the measure states a legitimate purpose on its face and is rationally related to that purpose, stray statements suggesting animus do not defeat the classification. The inquiry focuses on the stated objective and the rational connection rather than on extrinsic evidence of motive.
No. When the underlying classification receives only rational basis review, Congress must identify a pattern of unconstitutional state conduct and craft a congruent and proportional remedy. Statutes that prohibit far more constitutional conduct than unconstitutional conduct exceed Section Five authority.