reasonably related to a legitimate governmental objective
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Also known as:reasonably related · legitimate governmental objective · rational basis · rational basis test · rational basis review
Written by attorneys — see sources below.
A deferential standard requiring that government action or a regulation bear a rational connection to a valid public purpose. The standard is satisfied when the measure advances the identified objective without demanding a perfect fit or the least restrictive means.
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How its tested
Common Examples
6
Visa Restriction Upheld
The President issues an order barring entry by nationals from several majority-Muslim countries. Officials cite national security risks of infiltration into critical infrastructure projects. Courts apply the standard and uphold the order because the stated security purpose supplies a rational connection to the entry limits.
Inmate Communication Limits
A prison adopts rules restricting legal-assistance communications among inmates. Officials cite security and rehabilitation goals. Courts apply the standard and uphold the rules because the restrictions bear a rational connection to legitimate penological objectives.
School officials adopt a policy allowing warrantless searches of student lockers when they have reasonable grounds to suspect rule violations. The policy is challenged as unreasonable. Courts uphold it because the search measures are rationally related to the legitimate objective of maintaining school safety and discipline.
Lawyer Credential Disclosure
A state bar adopts a rule requiring lawyers who list professional certifications in ads to include a disclaimer that the state does not endorse the certifications. The rule is challenged as restricting commercial speech. Courts uphold the disclaimer requirement because it is rationally related to the legitimate objective of preventing consumer deception.
Contingent Fee Disclaimer
A state requires lawyers advertising contingent-fee arrangements to add a statement that clients may still owe costs even if there is no recovery. The rule is challenged as compelled speech. Courts uphold the requirement because the disclaimer is rationally related to the legitimate objective of preventing misleading advertisements.
Group Home Permit Denial
A city denies a special use permit for a group home for people with intellectual disabilities in a residential zone. City officials cite concerns about neighborhood safety and traffic. The denial fails the standard because the stated interests supply no rational connection to the permit decision.
City of Cleburne, Texas, et al. v. Cleburne Living Center, Inc., et al.473 U.S. 432, 105 S. Ct. 3249, 87 L. Ed. 2d 313 (1985)
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.
The standard is the most deferential form of review. Courts uphold the measure if any reasonably conceivable set of facts shows a rational connection to a legitimate governmental purpose.
Supporting sources
Does the standard require the government to choose the least restrictive means?
No. The standard does not demand narrow tailoring or the least burdensome alternative. A measure survives even if other, less intrusive options exist.
Supporting sources
Can statements of improper motive defeat an otherwise valid measure?
Under the standard, courts focus on the stated legitimate purpose and the rational connection to it. Extrinsic evidence of improper motive does not automatically invalidate the measure when a proper purpose appears on the face of the action.
Supporting sources
How does the standard apply to fees charged by common-interest communities?
Fees for services or use of common property must bear a rational connection to the actual costs incurred or the value of the service provided. Fees that exceed those costs without express authorization in the governing documents are invalid.
Supporting sources
When may states require disclaimers in lawyer advertising?
States may require factual, noncontroversial disclaimers when they are rationally connected to preventing consumer deception. Blanket prohibitions on truthful professional designations are not permitted.
Supporting sources
410 U.S. 113 (1973)
…in promoting its interest in the health of the mother, may, if it chooses, regulate the abortion procedure in ways that are reasonably related to maternal health. Pp. 163-164. (e) For the stage subsequent to viability, the State in promoting its interest in the potentiality of human life may, if it chooses, regulate, and even…