Also known as: rationally relates · rationally relating · rational relation · rational relationship · rational basis
Written by attorneys — see sources below.
A standard of judicial review under which legislation or a classification is upheld if it bears a rational relationship to a legitimate governmental interest.
The President issues an order barring pilots from several majority-Muslim countries after intelligence reports flag heightened hijacking risks at U.S. airports. Angelica, a foreign trainee denied entry, sues claiming religious animus. The court applies rational basis review and upholds the order because the stated national security purpose is rationally related to the entry limits.
Rajesh Rao files for bankruptcy to discharge student loans before applying to the state bar. The bar committee cites the filing as evidence of financial irresponsibility. The court sustains the denial because the inquiry into past financial conduct is rationally related to fitness to practice law.
A state statute criminalizes use of contraceptives by married couples. Ryan Roberts and his wife challenge the law after arrest. Because the statute burdens a fundamental liberty, the court holds that a mere rational relationship to a legitimate purpose is insufficient to sustain it.
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 casePennsylvania enacts spousal-notification rules for abortions. Renata Russo, a married woman seeking the procedure, sues. The Court applies the undue-burden standard rather than asking only whether the rules are rationally related to a legitimate interest.
The Pennsylvania Abortion Control Act of 1982, as amended in 1988 and 1989, established several requirements governing the performance of abortions within the Commonwealth. The Act required a woman seeking an abortion to provide informed consent after receiving specific information from a physician or counselor at least twenty-four hours before the procedure. It mandated that a minor obtain the informed consent of one parent, subject to a judicial bypass option. It further required a married woman to sign a statement confirming that she had notified her husband of her planned abortion, unless certain exceptions applied. The Act also imposed reporting obligations on facilities providing abortion services and defined a medical emergency exception to the various requirements. Before any of these provisions took effect, the petitioners brought suit in the United States District Court for the Eastern District of Pennsylvania. The petitioners were five abortion clinics and one physician representing himself as well as a class of physicians who provide abortion services. They sought declaratory and injunctive relief and challenged each provision as unconstitutional on its face. The District Court entered a preliminary injunction. After conducting a three-day bench trial, the District Court held all the provisions unconstitutional and entered a permanent injunction against their enforcement by Pennsylvania. The Court of Appeals for the Third Circuit affirmed in part and reversed in part. It adopted the District Court's factual findings and legal analysis except with respect to the spousal notification requirement. The Court of Appeals upheld the spousal notification requirement as constitutional and applied the undue burden standard in evaluating the provisions. The Supreme Court granted certiorari to consider the constitutionality of the challenged provisions of the Pennsylvania statute.
View caseEast Cleveland limits single-family homes to certain nuclear-family configurations. Roberto Reyes, a grandmother living with her grandson, faces eviction under the ordinance. The Court invalidates the rule because the classification bears no rational relationship to any legitimate density or traffic goal.
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 caseNew London condemns waterfront homes to assemble land for a private redevelopment project expected to increase tax revenue. Ronald Reed, an owner whose property is taken, sues under the Takings Clause. The Court upholds the taking because it is rationally related to the legitimate public purpose of economic revitalization.
In the late 1990s the city of New London, Connecticut, confronted severe economic decline after the 1996 closure of the Naval Undersea Warfare Center, which had employed more than 1,500 people. The city's unemployment rate stood nearly double the state average and its population had dropped below 24,000 residents from a 1970 high of 30,000. State and local officials therefore designated the Fort Trumbull peninsula for targeted economic revitalization. In 1998 the New London Development Corporation, a private nonprofit entity, was reactivated to prepare a redevelopment plan covering roughly 90 acres. The plan divided the area into seven parcels designated for a waterfront conference hotel and marinas, retail and entertainment space, research and office facilities, parking and park support, residential units, a Coast Guard museum, and additional office and retail uses. The city council formally approved the plan in January 2000 and authorized the NLDC to acquire needed parcels by purchase or, if necessary, by eminent domain. Petitioners Susette Kelo, Wilhelmina Dery, and seven other owners held fifteen properties within parcels 3 and 4A; ten of those parcels were occupied by the owners or their family members and none was alleged to be blighted. After negotiations with the NLDC failed, the corporation initiated condemnation proceedings against the remaining properties in November 2000. In December 2000 the petitioners filed suit in New London Superior Court asserting that the proposed takings violated the public-use limitation of the Fifth Amendment. Following a seven-day bench trial the Superior Court entered a permanent restraining order barring condemnation of the parcel 4A properties but denied relief as to the parcel 3 properties. Both sides appealed to the Connecticut Supreme Court, which upheld the validity of all challenged takings. The United States Supreme Court granted certiorari to review the federal constitutional question.
View caseA law or classification survives if it is rationally related to a legitimate governmental interest. Courts defer heavily to legislative judgments and uphold measures even when they are underinclusive or overinclusive.
No. Federal alienage classifications receive rational basis review because Congress holds plenary power over immigration. A residency or status distinction is upheld if rationally related to a legitimate objective such as conserving benefits or easing administration.
A regulation on incoming prisoner mail is valid if rationally related to legitimate penological interests such as security and order. Courts grant substantial deference to prison administrators in making that determination.
Rational basis requires only a rational relationship to a legitimate end. Intermediate scrutiny demands that the means be substantially related to an important governmental interest and places a heavier burden on the government.
…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…