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New York City Transit Authority v. Beazer

Supreme Court of the United States · 1979 · Constitutional Law

Constitutional LawEqual ProtectionTitle VIIRational Basis ReviewEqual Protection Clauserational basispublic employmentmethadone maintenance

Facts

The Transit Authority operated a large urban transit system and employed many workers in dangerous or safety-sensitive positions. It enforced Rule 11(b), a general rule against employing persons who use narcotic drugs, and it treated methadone as a narcotic; in practice, no written permission was ever granted for employing methadone users. The record showed that methadone maintenance can successfully treat many heroin addicts, especially after a period of treatment, but also showed that a significant number of participants, including some with more than a year in treatment, continued to abuse drugs or alcohol. The plaintiffs were current or recent methadone users who were discharged or denied employment because of participation in methadone maintenance programs.

Issue

Whether the Transit Authority's blanket exclusion of current methadone users from employment violated the Equal Protection Clause, and whether the record supported a Title VII violation based on disparate racial impact. The Court also addressed whether it should avoid the constitutional question because of other statutory issues.

Rule

A governmental classification not involving a suspect class or fundamental right satisfies equal protection if it bears a rational relationship to legitimate state objectives; perfection is not required, and a rule may stand even if it is somewhat overinclusive or underinclusive. In Title VII disparate-impact cases, statistical evidence may establish a prima facie case, but weak or irrelevant statistics do not prove a violation, and in any event a practice that is job related rebuts such a claim.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

The Dayton Regional Rail Service refuses to hire anyone currently enrolled in a physician-supervised methadone maintenance program for any position, including warehouse and clerical work. Several applicants in Columbus submit evidence that they have been compliant in treatment for 18 months and have no recent drug or alcohol problems.

If the applicants bring an equal protection challenge, which is the strongest argument for upholding the policy?

Explanation. Under the majority opinion, current methadone users are not a suspect class, and no fundamental right is involved. The government need only show a rational relationship to legitimate objectives such as safety and efficiency. A blanket rule may stand even if broader than necessary and even if individualized screening might be wiser as a personnel matter. The Constitution does not require the best or most precise line.