A sufficient connection or proportionality between conduct, a measure, or a condition and a legitimate legal objective or purpose.
See Our Sources· 17 primary sources
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How its tested
Common Examples
6
Out-of-State Lawyer in Tribunal Matter
Roberto Reyes, admitted only in State B, assists a client in a federal court proceeding pending in State A. He files papers and argues motions in that proceeding without local counsel. The services qualify as temporary practice because they are reasonably related to the pending tribunal matter and Reyes reasonably expects authorization to appear.
Homeowners Association Transfer Fee
Rowan Russell buys a home in a common-interest community governed by Redwood Bank. The association charges a $400 transfer fee to update membership records. The fee exceeds the actual administrative costs of record changes and is not tied to any special service value, so the charge fails the requirement that fees be reasonably related to costs.
Lawyer Advertising Professional Credentials
Ryan Roberts, a lawyer also licensed as a CPA, places an advertisement listing both credentials. State regulators seek to discipline him solely for the truthful listing. The listing is protected because any required disclaimer must be reasonably related to preventing actual or inherent deception rather than imposing a blanket ban.
Contingent-Fee Advertising Disclaimer
Renee Rogers advertises that clients pay no fee if there is no recovery. The state requires her to add a statement clarifying that clients may still owe costs. The mandated disclosure is permissible because it is reasonably related to preventing consumer deception about the scope of the contingent-fee arrangement.
Illegitimacy Classification for Benefits
Raymond Ramos, an illegitimate child, seeks surviving child insurance benefits after his father's death. The statute presumes dependency for some categories but requires proof from others. The classification survives because it is reasonably related to the likelihood of actual dependency at the time of death.
Trimble v. Gordon430 U.S. 762, 775 n.16 (1977)
Deta Mona Trimble is the illegitimate daughter of Jessie Trimble and Sherman Gordon. Trimble and Gordon lived together in Chicago with Deta Mona from 1970 until Gordon died in 1974 as the victim of a homicide. On January 2, 1973, the Circuit Court of Cook County, Illinois, entered a paternity order finding Gordon to be the father of Deta Mona and ordering him to pay fifteen dollars per week for her support. Gordon thereafter supported Deta Mona in accordance with the paternity order and openly acknowledged her as his child.
Gordon died intestate at the age of twenty-eight, leaving an estate consisting only of a 1974 Plymouth automobile worth approximately twenty-five hundred dollars. Shortly after Gordon's death, Trimble, as the mother and next friend of Deta Mona, filed a petition for letters of administration, determination of heirship, and declaratory relief in the Probate Division of the Circuit Court of Cook County. That court entered an order determining heirship, identifying as the only heirs of Gordon his father Joseph Gordon, his mother Ethel King, and his brother, two sisters, and a half brother. The Circuit Court excluded Deta Mona on the authority of section twelve of the Illinois Probate Act.
The Illinois Supreme Court affirmed the decision of the Circuit Court on the authority of its earlier decision in In re Estate of Karas. The United States Supreme Court noted probable jurisdiction to consider the arguments that section twelve violates the Equal Protection Clause of the Fourteenth Amendment by invidiously discriminating on the basis of illegitimacy and sex.
Terry Stop Scope of Search
Ravi Reddy is stopped on the street after an officer observes behavior suggesting he is casing a store for robbery. The officer pats down Reddy's outer clothing and finds a weapon. The pat-down is valid because it is reasonably related in scope to the officer's suspicion that Reddy is armed and dangerous.
Terry v. Ohio392 U.S. 1, 88 S.Ct. 1868, 20 L.Ed.2d 889 (1968)
On October 31, 1963, Cleveland police detective Martin McFadden, a 39-year veteran assigned to downtown Cleveland for 30 years, observed John W. Terry and Richard Chilton standing on the corner of Huron Road and Euclid Avenue.
McFadden took up a post of observation 300 to 400 feet away. He watched as the two men walked back and forth along Huron Road, pausing repeatedly to look in the window of a store before conferring with each other. This pattern repeated roughly a dozen times over ten to twelve minutes.
A third man, Katz, joined them briefly before departing, after which Terry and Chilton followed the same path. By this time McFadden had become thoroughly suspicious that the men were casing the store for a robbery and feared they might be armed.
McFadden approached the three men in front of Zucker's store, identified himself as a police officer, and asked their names. When they mumbled responses, he grabbed Terry, spun him around, patted down the outer clothing of his overcoat, and felt a pistol in the left breast pocket.
He removed a .38-caliber revolver from Terry's pocket and ordered the men into the store, where he similarly frisked Chilton and discovered another revolver while finding no weapons on Katz. Terry and Chilton were arrested and charged with carrying concealed weapons.
Prior to trial they moved to suppress the revolvers as the product of an unlawful search. The trial court denied the motion after hearing McFadden's testimony, finding that the officer had reasonable cause to believe the defendants were acting suspiciously and that the frisk was necessary for his protection. After the denial, Terry and Chilton waived jury trial, were convicted, and sentenced to one to three years in the penitentiary. The Ohio Court of Appeals affirmed, the Supreme Court of Ohio dismissed the appeal, and the United States Supreme Court granted certiorari.
5 common questions
Students Frequently Ask...
How does the reasonably related standard affect whether an out-of-state lawyer may provide temporary services in another jurisdiction?
The standard permits temporary practice when the services are in or reasonably related to a pending or potential proceeding before a tribunal, provided the lawyer is authorized or reasonably expects authorization to appear. It also applies to services reasonably related to the lawyer's home-state practice when they arise out of or are connected to that practice.
When are association fees or charges valid under the reasonably related test in common-interest communities?
Fees for services or use of common property must be reasonably related to the costs of providing the service or maintaining the property, or to the value of the use or service, unless the declaration expressly authorizes a different amount. This prevents the association from using fees to force a minority to subsidize benefits for others.
Supporting sources
What role does the reasonably related standard play in evaluating lawyer advertising regulations?
States may require factual, noncontroversial disclosures in lawyer advertising when the requirements are reasonably related to preventing consumer deception and are not unduly burdensome. Blanket bans on truthful professional certifications or illustrations fail this test absent evidence that the statements are actually or inherently misleading.
Supporting sources
How does the reasonably related test apply to prison regulations affecting inmate rights?
Regulations restricting inmate communications or other constitutional interests are valid if reasonably related to legitimate penological interests such as security, rehabilitation, or institutional order. Courts apply this deferential standard rather than heightened scrutiny when evaluating restrictions on legal assistance or similar activities.
In contract remedies, when is a liquidated damages amount enforceable under the reasonably related standard?
A liquidated damages clause is enforceable only if the fixed amount is reasonably related to the anticipated or actual harm caused by breach, considering the difficulty of proving loss and the inconvenience of obtaining another remedy. An amount that materially exceeds that reasonable relationship is treated as an unenforceable penalty.
Supporting sources
to the promotion of the general welfare, uniformly reject the proposition that diminution in property value, standing alone, can establish a “taking,” see Euclid v. Ambler Realty Co. ,…
Constitutional LawThe separation of powers · The powers of CongressUBEIntermediate