Also known as: inexplicable except by animus · animus · bare animus
Written by attorneys · grounded in primary & secondary sources — see below
A description of a classification or government action for which no legitimate purpose can be identified. Courts then conclude that the measure rests on impermissible prejudice or hostility rather than any rational basis.
Alpha Framing, a construction firm, challenged an executive order temporarily barring skilled workers from several majority-Muslim nations. The order recited national-security concerns tied to infrastructure projects in State A. Because the stated rationale aligned with legitimate vetting needs and the order applied only temporarily, the court found the measure rationally related to security and rejected the claim that it was inexplicable by anything but animus.
Masterpiece Cakeshop declined to create a wedding cake for a same-sex couple. State officials then pursued enforcement with evident hostility toward the baker's religious beliefs. The commission's treatment of the case revealed comments and procedures showing the decision was inexplicable by anything but animus toward religion.
Select any source to read its text and confirm it supports the definition.
After a guilty verdict, two jurors reported that a fellow juror had made explicit statements invoking racial stereotypes about the defendant. The trial court considered affidavits showing the statements reflected racial animus as a significant motivating factor in the vote. Because the comments could not be explained by any legitimate view of the evidence, the court found the verdict inexplicable by anything but animus.
Mississippi University for Women maintained a policy excluding men from its nursing program. The state offered no credible justification tied to educational quality or privacy that explained the exclusion. The Supreme Court concluded the single-sex rule was inexplicable by anything but animus toward men seeking the same professional training.
City officials discarded the results of a firefighter promotion exam because minority candidates had not performed as well. No evidence showed the test was invalid or that discarding the results served any legitimate nondiscriminatory goal. The decision was therefore inexplicable by anything but animus toward the higher-scoring applicants.
During jury selection in a paternity and child-support case, the state used peremptory challenges to remove all male jurors. The prosecutor offered no explanation linked to the facts of the case that justified striking every man. The pattern was inexplicable by anything but animus on the basis of gender.
A policy meets this description when no legitimate governmental interest can be identified to support it. Courts then infer that the measure rests on prejudice rather than any rational basis.
Supporting sources
No. When the policy text supplies a legitimate purpose and the action is rationally related to that purpose, courts uphold it even if stray statements suggest animus.
Supporting sources
Courts apply at most rational-basis review and defer to the political branches. A facially neutral national-security rationale ordinarily defeats a claim that the action is inexplicable by anything but animus.
Supporting sources
…Clause protects intimate personal choices. Lawrence v. Texas , 539 U. S. 558. The Court has also invalidated laws based on the animus toward a class of people. See Romer v. Evans , 517 U. S. 620. Against this background, the legal question of same-sex marriage must be addressed. Pp. 10–15. (2) The nature of marriage is…