Supreme Court of the United States · 1991 · Constitutional Law
501 U.S. 452 (1991)
Updated
Constitutional LawFederalismAge Discrimination in Employment ActEqual Protectionstate sovereigntyADEAstate judgesplain statement
Facts
The Missouri Constitution requires all judges other than municipal judges to retire at age 70. Petitioners were Missouri judges appointed by the Governor under the Missouri Non-Partisan Court Plan and later retained through unopposed retention elections. They challenged the mandatory retirement provision under the ADEA and the Fourteenth Amendment's Equal Protection Clause. Missouri argued that appointed judges were excluded from the ADEA as appointees on the policymaking level and that the age classification was constitutionally rational.
Issue
Whether Missouri's constitutional provision requiring judges to retire at age 70 violates the ADEA, and whether the provision denies equal protection of the laws under the Fourteenth Amendment.
Rule
When federal legislation would alter the usual constitutional balance between the States and the Federal Government, especially in an area at the heart of state sovereignty such as prescribing qualifications for important state officials, Congress must make its intention unmistakably clear in the language of the statute. Age classifications that burden neither a suspect class nor a fundamental right are reviewed under rational basis review and are valid if rationally related to any legitimate state purpose.
🔒
See the holding & full analysis
Create a free KwikCourt account to unlock the rest of this brief — and practice the case.
The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
The Franklin Constitution requires members of its Public Utilities Commission to leave office at age 72. Congress later amends a federal age-discrimination statute to cover all state employers, but the statute does not mention state constitutional officers and excludes certain elected officials, personal staff, appointees on the policymaking level, and immediate advisers. Lena Ortiz, an appointed commissioner in Columbus, challenges the retirement rule under the federal statute.
How should a court most likely rule on Lena's statutory claim?
Explanation. The majority required an unmistakably clear statement before reading federal law to intrude on a state's decision about qualifications for important state officials, a core sovereign function. Because the statute's exclusions make coverage of high-ranking appointees at least ambiguous, a court should not read it to reach the appointed commissioner absent clear inclusion.