Misplaced Pages

Revision as of 20:57, 17 February 2007

U.S. Supreme Court cases Unassessed

This article is part of WikiProject U.S. Supreme Court cases, a collaborative effort to improve articles related to Supreme Court cases and the Supreme Court. If you would like to participate, you can edit the article attached to this page, or visit the project page.U.S. Supreme Court casesWikipedia:WikiProject U.S. Supreme Court casesTemplate:WikiProject U.S. Supreme Court casesU.S. Supreme Court ??? This article has not yet received a rating on Misplaced Pages's content assessment scale. ??? This article has not yet received a rating on the importance scale.

This article is full of half truths and outright falsehoods that the first author wrote in to try to buttress their false claims on the state's rights page. See discussion there for some of the issues. 69.105.0.115 22:18, 20 August 2006 (UTC)

For instance the summary of the finding of the case says "The Court held that Congress's enforcement powers under the Fourteenth Amendment to the Constitution did not extend to the abrogation of state sovereign immunity under the Eleventh Amendment where the discrimination complained of was based on age. Therefore the Age Discrimination in Employment Act of 1967 (ADEA or Act) does not apply to states."

Whereas the courts actual summary of the decision states"Although the ADEA does contain a clear statement of Congress’ intent to abrogate the States’ immunity, that abrogation exceeded Congress’ authority under §5 of the Fourteenth Amendment."

and "Congress cannot, however, decree the substance of the Fourteenth Amendment’s restrictions on the States. Id., at 519. The ultimate interpretation and determination of the Amendment’s substantive meaning remains the province of the Judicial Branch. This Court has held that for remedial legislation to be appropriate under §5, “here must be a congruence and proportionality between the injury to be prevented or remedied and the means adopted to that end.”

and "States therefore may discriminate on the basis of age without offending the Fourteenth Amendment if the age classification in question is rationally related to a legitimate state interest. The rationality commanded by the Equal Protection Clause does not require States to match age distinctions and the legitimate interests they serve with razorlike precision. Rather, a State may rely on age as a proxy for other qualities, abilities, or characteristics that are relevant to the State’s legitimate interests. That age proves to be an inaccurate proxy in any individual case is irrelevant. Judged against the backdrop of this Court’s equal protection jurisprudence, it is clear that the ADEA is “so out of proportion to a supposed remedial or preventive object that it cannot be understood as responsive to, or designed to prevent, unconstitutional behavior."

So this articles summary leaves out the fact that only irrational discrimination based on age is permitted. States may not simply discriminate by age willy nilly, as this article seems to imply, but can rationally discriminate based on age, such as assuming in general older people can't do as much work as younger people 69.105.0.115 22:39, 20 August 2006 (UTC)

And this statement is false "the equal protection clause applies to state governments only for discrimination based on "race or gender." This is not true, and does not say that in decision.

Section C, Paragraphs 1-3 state "Applying the same “congruence and proportionality” test in these cases, we conclude that the ADEA is not “appropriate legislation” under §5 of the Fourteenth Amendment. Initially, the substantive requirements the ADEA imposes on state and local governments are disproportionate to any unconstitutional conduct that conceivably could be targeted by the Act. We have considered claims of unconstitutional age discrimination under the Equal Protection Clause three times. See Gregory v. Ashcroft, 501 U.S. 452 (1991); Vance v. Bradley, 440 U.S. 93 (1979); Massachusetts Bd. of Retirement v. Murgia, 427 U.S. 307 (1976) (per curiam). In all three cases, we held that the age classifications at issue did not violate the Equal Protection Clause. See Gregory, supra, at 473; Bradley, supra, at 102—103, n. 20, 108—112; Murgia, supra, at 317. Age classifications, unlike governmental conduct based on race or gender, cannot be characterized as “so seldom relevant to the achievement of any legitimate state interest that laws grounded in such considerations are deemed to reflect prejudice and antipathy.” Cleburne v. Cleburne Living Center, Inc., 473 U.S. 432, 440 (1985). Older persons, again, unlike those who suffer discrimination on the basis of race or gender, have not been subjected to a “ ‘history of purposeful unequal treatment.’ ” Murgia, supra, at 313 (quoting San Antonio Independent School Dist. v. Rodriguez, 411 U.S. 1, 28 (1973)). Old age also does not define a discrete and insular minority because all persons, if they live out their normal life spans, will experience it. 427 U.S., at 313—314. Accordingly, as we recognized in Murgia, Bradley, and Gregory, age is not a suspect classification under the Equal Protection Clause. See, e.g., Gregory, supra, at 470; Bradley, supra, at 97; Murgia, supra, at 313—314.

States may discriminate on the basis of age without offending the Fourteenth Amendment if the age classification in question is rationally related to a legitimate state interest. The rationality commanded by the Equal Protection Clause does not require States to match age distinctions and the legitimate interests they serve with razorlike precision. As we have explained, when conducting rational basis review “we will not overturn such unless the varying treatment of different groups or persons is so unrelated to the achievement of any combination of legitimate purposes that we can only conclude that the actions were irrational.” Bradley, supra, at 97. In contrast, when a State discriminates on the basis of race or gender, we require a tighter fit between the discriminatory means and the legitimate ends they serve. See, e.g., Adarand Constructors, Inc. v. Peña, 515 U.S. 200, 227 (1995) (“ classifications are constitutional only if they are narrowly tailored measures that further compelling governmental interests”); Mississippi Univ. for Women v. Hogan, 458 U.S. 718, 724 (1982) (holding that gender classifications are constitutional only if they serve “ ‘important governmental objectives and … the discriminatory means employed’ are ‘substantially related to the achievement of those objectives’ ” (citation omitted)). Under the Fourteenth Amendment, a State may rely on age as a proxy for other qualities, abilities, or characteristics that are relevant to the State’s legitimate interests. The Constitution does not preclude reliance on such generalizations. That age proves to be an inaccurate proxy in any individual case is irrelevant. “here rationality is the test, a State ‘does not violate the Equal Protection Clause merely because the classifications made by its laws are imperfect.’ ” Murgia, supra, at 316 (quoting Dandridge v. Williams, 397 U.S. 471, 485 (1970)). Finally, because an age classification is presumptively rational, the individual challenging its constitutionality bears the burden of proving that the “facts on which the classification is apparently based could not reasonably be conceived to be true by the governmental decisionmaker.” Bradley, supra, at 111; see Gregory, supra, at 473.

Our decisions in Murgia, Bradley, and Gregory illustrate these principles. In all three cases, we held that the States’ reliance on broad generalizations with respect to age did not violate the Equal Protection Clause. In Murgia, we upheld against an equal protection challenge a Massachusetts statute requiring state police officers to retire at age 50. The State justified the provision on the ground that the age classification assured the State of the physical preparedness of its officers. 427 U.S., at 314—315. Although we acknowledged that Officer Murgia himself was in excellent physical health and could still perform the duties of a state police officer, we found that the statute clearly met the requirements of the Equal Protection Clause. Id., at 311, 314—317. “That the State chooses not to determine fitness more precisely through individualized testing after age 50 that the objective of assuring physical fitness is not rationally furthered by a maximum-age limitation.” Id., at 316. In Bradley, we considered an equal protection challenge to a federal statute requiring Foreign Service officers to retire at age 60. We explained: “If increasing age brings with it increasing susceptibility to physical difficulties, … the fact that individual Foreign Service employees may be able to perform past age 60 does not invalidate any more than did the similar truth undercut compulsory retirement at age 50 for uniformed state police in Murgia.” 440 U.S., at 108. Finally, in Gregory, we upheld a provision of the Missouri Constitution that required judges to retire at age 70. Noting that the Missouri provision was based on a generalization about the effect of old age on the ability of individuals to serve as judges, we acknowledged that “t is far from true that all judges suffer significant deterioration in performance at age 70,” “t is probably not true that most do,” and “t may not be true at all.” 501 U.S., at 473. Nevertheless, because Missouri’s age classification was subject only to rational basis review, we held that the State’s reliance on such imperfect generalizations was entirely proper under the Equal Protection Clause. Ibid. These decisions thus demonstrate that the constitutionality of state classifications on the basis of age cannot be determined on a person-by-person basis. Our Constitution permits States to draw lines on the basis of age when they have a rational basis for doing so at a class-based level, even if it “is probably not true” that those reasons are valid in the majority of cases."

The decision stated age is not in general a suspect classification, not that the 14th does not apply to it, and that one must prove general irrational discrimination to make the case. 69.105.0.115 22:57, 20 August 2006 (UTC)

So what's your problem? Didn't you just prove that you're wrong again?Jimmuldrow 05:30, 21 August 2006 (UTC)

You keep saying decision said 14th did not apply to age discrimination and that state's may now always discriminate against the elderly, when it clearly says 14th does not apply to rational discrimination 69.105.0.115 05:40, 21 August 2006 (UTC)

And applying the rational argument on the individual level would be the "razorlike precision" that the majority opinion said is not required.

Also, O'Connor's decision said, "Under the Fourteenth Amendment, a State may rely on age as a proxy for other qualities, abilities, or characteristics that are relevant to the State’s legitimate interests. The Constitution does not preclude reliance on such generalizations. That age proves to be an inaccurate proxy in any individual case is irrelevant." Jimmuldrow 19:58, 21 August 2006 (UTC)

There are a few substantive problems with this article, although it probably needs a comprehensive stylistic revision as well. First, it is undisputed that Ex parte Young allows a state official to be sued for prospective injunctive relief under the ADEA (and other federal laws). The article implies that the ability of injured plaintiffs to receive equitable relief is in doubt, and this is untrue. Second, the summary of Boerne is too long and contains statements of opinion (e.g., about the effect of Katzenbach) and loaded terms like "states' rights." Third, the reference to Adam Winkler's article is both dubious in relevance and incorrect in substance. It is dubious in relevance because it deals with an issue which is only tangentially related to the issue in Kimel. It is incorrect in substance because Winkler's article actually says that 70% of the statutes analyzed under strict scrutiny fail. The 20% figure, as far as I can tell, comes from the percentage of statutes which have survived strict scrutiny in the early 2000s; the text of this article, whose summary of the Winkler article is somewhat opaque, appears to say otherwise. Hydriotaphia 20:57, 17 February 2007 (UTC)

• Unassessed U.S. Supreme Court articles
• Unknown-importance U.S. Supreme Court articles
• WikiProject U.S. Supreme Court cases articles