Agenda - Council - 12/20/1983 - Laserfiche WebLink

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I I I Page -2- Defendants have taken great solace in the statements of various courts that to survive a constitutional attack based on equal protection a law need only be rationally related to its legislative purpose. In so stating the proposition, the defendants sidestep and avoid addressing the question of what it means for a piece of legislation to be rationally related to its purpose. Logic alone compels one to the conclusion that in order to be rationally related to a legislative purpose the law must in some manner promote that purpose or achieve it. But logic alone does ' not dictate this result. In Minnesota v. Clover Leaf Creamery Co., 449 US 456, 101 S. Ct. 715 (1981) Justice Brennan defined the issue central to an equal protection case as follows: "Thus, the controversy in this case centers on the narrow issue whether the legislative classification between plastic and non- plastic, non-returnable milk containers is rationally rel%ted to achievement of the statutory purposes." Id. at 462-463 (emphasis added). Plaintiffs acknowledge that the constitution does not require a perfect fit between legislative purpose and the achievement of that purpose but one can hardly determine whether a statute is rationally related to its purposes unless one considers whether that statute achieves or promotes its purposes. Defendants have cited the Clover Leaf case to the court but have failed to identify the very issue with which the court was grappling. The United States Supreme Court in Holt Civic Club v. City of Tuscaloosa, 439 US 60, 99 $. Ct. 383, 58 L.Ed. 292 (1978) stated the test in this fashion: "'The Fourteenth Amendment does not prohibit legislation merely because it is special or limited in its application to a particular geographical or political subdivision of the state.' . . (cites omitted) Rather, the Equal PrOtection Clause is offended only if that statute's classification 'rests on grounds wholly irrelevant to the achievement of the state's objective'" Id. 439 U.S. at 70-71, 99 S. Ct. at 390. Five years earlier in McGinnis v. Royster, 410 U.S. 263, 270, 93 S. Ct. 1055, 1059, 35 L.Ed.2d 282 (1973) the court phrased the inquiry as whether the challenged legislative distinctions rationally further sDme legitimate articulated state purpose.