Also known as: rational means test · rational-means-test · rational basis test · rational basis review
Written by attorneys — see sources below.
A standard of judicial review under which a law or government action is upheld if it is rationally related to a legitimate governmental interest. Courts applying the test defer to legislative or executive judgments and uphold measures even when they are underinclusive or overinclusive.
Roberto Reyes, a 51-year-old officer with excellent fitness scores, challenges the department's rule ending employment at age 50. The department defends the cutoff as a means to maintain a physically capable force. The court upholds the rule because the age line bears a rational connection to the department's interest in officer safety and performance.
Rina Rahman, a software engineer from a majority-Muslim country, is denied a visa under an executive order citing cybersecurity risks to defense contractors. She sues, pointing to earlier statements by officials suggesting religious animus. The court sustains the order because it recites a national-security purpose rationally advanced by the country-based restrictions.
Rosa Ruiz, a parent in a low-property-wealth district, challenges the state's reliance on local property taxes to fund schools. She argues the system produces unconstitutional inequality. The court applies the test and upholds the funding method because it is rationally related to the state's interest in preserving local control over education.
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.
View caseRiverfront Developments, a domestic insurer, challenges a state tax statute that grants preferential treatment only to insurers domiciled in the state. The company claims the distinction lacks any rational basis. The court upholds the exemption because it rationally advances the state's interest in encouraging local investment and regulatory oversight.
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.
View caseRonald Reed is prosecuted under a federal statute banning firearms within 1,000 feet of a school. He moves to dismiss, arguing Congress lacked power to enact the prohibition. The court strikes down the statute because the connection between gun possession near schools and interstate commerce is too attenuated to satisfy the test.
In March 1992, Alfonso Lopez, Jr., a twelfth-grade student at Edison High School in San Antonio, Texas, arrived at school carrying a concealed .38-caliber handgun and five bullets. Acting on an anonymous tip, school authorities confronted Lopez, who admitted possessing the weapon. Local police arrested him and charged him under Texas law with firearm possession on school premises. The following day, state charges were dismissed after federal agents charged Lopez with violating the Gun-Free School Zones Act of 1990. A federal grand jury indicted him on one count of knowing possession of a firearm at a school zone. Lopez moved to dismiss the indictment, arguing that the statute exceeded Congress's power to legislate control over public schools. The district court denied the motion, concluding that the statute was a constitutional exercise of Congress's power to regulate activities affecting commerce because the business of schools affects interstate commerce. After a bench trial, the court found Lopez guilty and sentenced him to six months' imprisonment and two years of supervised release. Lopez appealed to the Court of Appeals for the Fifth Circuit, which reversed the conviction, holding that the statute was beyond Congress's power under the Commerce Clause. The Supreme Court granted certiorari to review the case.
View caseRenata Russo, a state employee over age 40, sues her employer for money damages under the Age Discrimination in Employment Act. The state moves to dismiss on Eleventh Amendment grounds. The court holds that Congress lacked power under Section 5 to abrogate state immunity because age classifications receive only the test and the statute's remedies are not congruent and proportional to any pattern of unconstitutional state conduct.
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.
View caseAge is not a suspect or quasi-suspect class, so laws drawing age lines receive the rational-means test. A mandatory retirement age for police officers is therefore constitutional if rationally related to a legitimate objective such as maintaining a physically capable force.
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Courts apply at most the rational-means test and accord substantial deference to the political branches. An entry restriction is upheld if it states a facially legitimate national-security purpose and bears a rational relationship to that purpose, even when statements suggest improper animus.
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Congress may not subject states to private damages suits under statutes that prohibit far more conduct than the Constitution forbids under the rational-means test. Remedies must be congruent and proportional to a documented pattern of unconstitutional state discrimination.
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…(1996); Nordlinger v. Hahn , 505 U. S. 1, 11-12 (1992). Laws such as economic or tax legislation that are scrutinized under rational basis review normally pass constitutional muster, since "the Constitution presumes that even improvident decisions will eventually be rectified by the democratic processes." Cleburne v. Cleburne Living…