rationally related to a legitimate government purpose
/RASH-uh-nuh-lee ruh-LAY-tid too uh luh-JIT-uh-mit GUH-vurn-muhnt PUR-puhs/·principle
Also known as:rationally related · legitimate government purpose · rational basis test · rational basis review · rational basis scrutiny
Written by attorneys — see sources below.
A standard of judicial review under which legislation or governmental action is upheld if it bears a reasonable relationship to any legitimate governmental objective not prohibited by the Constitution. Courts accept any conceivable purpose and require only that the means chosen appear rationally connected to that end. The test supplies the lowest level of scrutiny and applies to classifications that neither burden fundamental rights nor target suspect classes.
See Our Sources· 8 primary sources
Cases
How its tested
Common Examples
6
National Security Entry Restriction
President issues an order barring entry of pilots from several majority-Muslim countries after intelligence reports flag heightened hijacking risks at U.S. airports. Angelica, a foreign national seeking pilot training, sues claiming the order stems from religious animus. The court upholds the order because its stated national-security objective supplies a legitimate purpose and the entry limits advance that purpose under deferential review.
State Marriage Recognition Statute
A state statute limits marriage to opposite-sex couples. Ryan Roberts and Ronald Reed, a same-sex couple, challenge the statute after their out-of-state marriage is not recognized. The court sustains the statute because the state advances the legitimate purpose of regulating domestic relations and the classification is rationally connected to that end.
Obergefell v. Hodges576 U.S. 644 (2015)
The petitioners were fourteen same-sex couples and two men whose same-sex partners were deceased. They lived in Michigan, Kentucky, Ohio, and Tennessee. Those states defined marriage as a union between one man and one woman under their constitutions and statutes.
The petitioners filed suits in federal district courts in their home states. They sought marriage licenses or recognition of marriages lawfully performed elsewhere. James Obergefell and John Arthur traveled from Ohio to Maryland to marry aboard a medical transport plane because Arthur suffered from ALS; Obergefell later sought to be listed as surviving spouse on Arthur's death certificate. April DeBoer and Jayne Rowse, Michigan nurses, adopted three children but could not both serve as legal parents under state adoption rules. Army Reserve Sergeant Ijpe DeKoe and Thomas Kostura married in New York before DeKoe's deployment to Afghanistan and later settled in Tennessee.
Each district court ruled in the petitioners' favor. The respondents appealed. The Sixth Circuit consolidated the cases and reversed the district court judgments. The petitioners sought certiorari, which the Supreme Court granted.
Same-sex couples had begun establishing families after substantial cultural and political developments in the late twentieth century. Earlier litigation had addressed the legal status of gays and lesbians, including challenges that reached the Supreme Court in Bowers v. Hardwick and Lawrence v. Texas.
Pennsylvania enacts a statute requiring spousal notification before an abortion. Rosalind Reed challenges the provision after her husband objects. The court upholds the requirement because the state asserts legitimate interests in potential life and marital integrity and the rule is rationally related to those interests.
Planned Parenthood of Southeastern Pennsylvania v. Casey505 U.S. 833, 112 S. Ct. 2791, 120 L. Ed. 2d 674 (1992)
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.
Housing Occupancy Ordinance
East Cleveland adopts an ordinance limiting occupancy to members of a nuclear family. Roger Ramirez, who lives with his grandson, faces eviction under the rule. The court strikes the ordinance because it lacks any rational relationship to the city's asserted interests in density control and traffic reduction.
Moore v. City of East Cleveland, Ohio431 U.S. 494, 503 (1977)
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.
Economic Development Taking
New London approves a redevelopment plan that transfers private homes to commercial developers. Ricardo Rojas, whose property is condemned, claims the taking serves only private interests. The court upholds the plan because economic revitalization constitutes a legitimate public purpose and the transfer is rationally related to that purpose.
Kelo, et al. v. City of New London545 U.S. 469, 503 (2005)
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.
School Funding Disparity
Texas funds public schools primarily through local property taxes, producing wide spending gaps between districts. Riley Rivera, a student in a low-wealth district, sues claiming the system denies equal educational opportunity. The court sustains the funding scheme because local control of education supplies a legitimate purpose and the tax-based method is rationally related to that purpose.
San Antonio Independent School District v. Rodriguez411 U.S. 1, 93 S. Ct. 127, 36 L. Ed. 2d 16 (1973)
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.
4 common questions
Students Frequently Ask...
What level of scrutiny applies when a classification receives rational basis review?
Rational basis review asks only whether the classification is rationally related to a legitimate government purpose. Courts accept any conceivable legitimate purpose and require only a reasonable connection between the means and that end. This standard is highly deferential and upholds nearly all economic and social legislation.
Supporting sources
Does a law fail rational basis review if it is underinclusive or overinclusive?
No. Under rational basis review a law may be underinclusive or overinclusive so long as it is rationally related to a legitimate purpose. Courts permit legislatures to address problems incrementally and accept imperfect classifications.
Supporting sources
How does rational basis review differ from strict scrutiny in equal protection cases?
Rational basis review requires only a rational relationship to a legitimate purpose, while strict scrutiny demands a compelling interest and narrow tailoring. Federal alienage classifications and most economic regulations receive rational basis review rather than strict scrutiny.
Supporting sources
Can statements suggesting improper motive defeat a law that states a legitimate purpose?
No. Under rational basis review the court examines whether the stated purpose is legitimate and rationally advanced by the measure. Extrinsic statements suggesting bias do not invalidate the law when the text supplies an independent legitimate objective.
Supporting sources
governmental
purpose
. The line drawn by the city between a grandmother living with the children of her son and a grandmother living with the children of her daughter is…
, I would uphold the Pennsylvania statute in its entirety. I must, however, respond to a few of the more outrageous arguments in today's opinion, which it is beyond human nature to leave…
Government
interest, a voluntary submission of data by an applicant in exchange for the economic advantages of a registration can hardly be called a taking." Id. , at…
Constitutional LawIndividual rights · Equal protectionUBEIntermediate