Case Brief Notes 1 PDF

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Professor Ron Den Otter...

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New Orleans v Dukes ● Ordinance banned all pushcart food vendors in French quarter expect those who had continuously operated for 8 or more years ○ 2 vendors had done 20 or more years and qualified under the “grandfather clause ○ Appelle who had operated a pushcart for only 2 years, attacked the ordinance ● Legitimate state interest- their objective is “to preserve the appearance and custom valued by the quarter's residents and attractive to tourists” ● Legislative classifications- drawing a distinction between those who had been there for 8 years and those who had been there for 2 years ● Because they have a legitimate legislative classification and their legislative classification is rationally related to their objective of wanting “to preserve the appearance and custom valued by the quarter's residents and attractive to tourists” , it does not violate Equal Protections Clause

Quimbee ● Facts: New Orleans ordinance banned all pushcart vendors from the French Quarter except those who had been there for 8+ years. Dukes sues under the EPC, saying that there’s no good reason to allow them but discriminate against him just because he’s only been there for 2 years. ● This legislation is rationally related to the legitimate state interest of preserving the appearance of the French Quarter. If the legislature wants to promote this interest in steps, by only limiting certain pushcart vendors right now, that’s their prerogative. It doesn’t violate the EPC. ●

New York City Transit v Beazer ● ● ●

Legislative classifications- Excluding all methadone users from any Transit Authority (TA) employment The legislative objective is safety and efficiency Overinclusion- does not allow anyone who uses narcotics but this includes those methadone users who are able to perform their duties efficiently and safely ○ Overinclusive because some methadone users would have presented none of the risks associated with illegal drug use ○ They subject all narcotics users to not being employed, even though not every person within this class may pose a problem that the legislators seek to address

Oyez ● held that the Transit Authority's policy was not unconstitutional or illegal under the Civil Rights Act. Writing for the majority, Justice Stevens described Beazer's statistical argument as "weak", as the 81 percent statistic did not relate to methadone users specifically. The Court recognized the public safety interest in keeping narcotics users from working for NYTA. The narcotics rule was an allowable policy choice made by NYTA, and any specific exemption for methadone users from the narcotics rule would have been "costly" and "imprecise."

US R.R. Retirement BD v Fritz ● Facts: In 1974 Congress passed the Railroad Retirement Act, which restructured the retirement system previously established in 1937. Under the old system, employees who were eligible for both railroad benefits and social security benefits received both, along with an additional “windfall” benefit. Since this system threatened to bankrupt the railroad retirement program, the goal of the new Act was to eliminate some of these benefits. The new Act divided employees into different classes based on their employment history as of January 1, 1975. Employees who had worked for the railroad fewer than 10 years would not receive any windfall benefit. Employees who were already retired and receiving the full benefits would continue to do so. Employees who qualified for the full benefits but had not yet retired would receive the full benefits only if they had a current connection to the railroad industry or had served for 25 years or more. Employees who did not meet these requirements received a lesser windfall benefit. ● The appellee Gerhard H. Fritz was part of a plaintiff class of former railroad

employees who were eligible for the windfall benefits under the old system, but who did not have a current connection to the railroad and had worked fewer than 25 years. Alleging that the Act created an irrational distinction between employees that violated the Due Process Clause, they filed a class action suit in district court. The district court held that such a distinction was not “rationally related” to the goal of ensuring the solvency of the retirement system. Conclusion: ● Justice William H. Rehnquist delivered the opinion of the 7-2 majority. The Court held that laws may create classifications that are not elegant or “artfully drawn” but that are not unconstitutional. The Constitution would allow Congress to deny windfall benefits to all employees, therefore it was not unconstitutional to deny them to some. The Court also held that the distinctions were not arbitrary, as Congress was attempting to “protect the relative equities of employees and to provide benefits to career railroad employees.” ●

In his concurring opinion, Justice John Paul Stevens wrote that the statute deserved more consideration to determine whether the adverse impact was a deliberate aim or an acceptable cost of the legislation. Since the Act had two conflicting aims — to protect the solvency of the retirement program and to ensure that employees received the benefits they earned — he argued that the statute in question legitimately pursues those goals. Congress had to make cuts in order to ensure the solvency, and length of service was a fair method of drawing distinctions.

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Justice William J. Brennan, Jr. wrote a dissent where he argued that a “principal purpose” of the Act was to ensure that the employees received the benefits that they earned. Since this statute directly conflicts with the stated goal, the classification cannot

be rationally based on the legislation. He also disagreed with the Court’s analysis that did not consider the effect of the statute in relation to its purpose. Justice Thurgood Marshall joined in the dissent....