LSTD 510 5-1 INTERESTS OF THE STATE

INTRODUCTION TO LSTD 510 5-1 Interests Of The State 

This Owlisdom, LSTD 510 5-1 Interests Of The State assignment involves exploring the rational basis test, a standard of judicial review used to evaluate laws affecting constitutional rights when neither a fundamental right nor a protected class is involved. You will analyze three key Supreme Court cases to understand how this test is applied and assess whether it effectively balances individual freedoms and government interests.

• Give an introduction

Example

The rational basis test is the most lenient form of judicial review used by courts to evaluate laws that affect constitutional rights. The test is applied when neither a fundamental right nor a protected class is involved. It requires that a law be rationally related to a legitimate government interest. The test’s application is explored in three landmark cases: Plyler v. Doe, City of Cleburne v. Cleburne Living Center, Inc., and Kadrmas v. Dickinson Public Schools.

Review Plyler v. Doe, 457 U.S. 202 (1982), City of Cleburne v. Cleburne Living Center, Inc., 473 U.S. 432 (1985), Kadrmas v. Dickinson Pub. Schools, 487 U.S. 450 (1988).

• Plyler v. Doe: Examine the LSTD 510 5-1 Interests Of The State  Court’s decision to strike down a Texas statute denying education funding to children who were illegal immigrants.
• City of Cleburne v. Cleburne Living Center, Inc.: Study the ruling on a city ordinance requiring a special permit for a group home for mentally disabled individuals.
• Kadrmas v. Dickinson Pub. Schools: Review the Court’s decision to uphold a North Dakota statute allowing school districts to charge transportation fees.

Why did each of these cases use the rational basis standard?  Explain the Court’s reasoning in each case. Did any of the cases cite and/or discuss the other cases as it analyzed the rational basis test application? Did the Court’s reasoning change regarding the issues presented?

RATIONAL BASIS REVIEW IN SUPREME COURT CASES

Plyler v. Doe, 457 U.S. 202

• Discuss LSTD 510 5-1 Interests Of The State why the Court applied a more exacting version of the rational basis test due to the vulnerable status of children.

In Plyler v. Doe, the Supreme Court struck down a Texas statute that denied funding for education to children who were illegal immigrants. The Court used a more exacting version of the rational basis test because it dealt with vulnerable individuals—children—whose status as illegal immigrants was not of their own making (Plyler v. Doe, 1982). The Court concluded that denying these children an education would not logically further the state’s interest in limiting illegal immigration or reducing costs, as the long-term costs of undereducating these children would far outweigh the savings made by the statute.

City of Cleburne v. Cleburne Living Center, Inc., 473 U.S. 432

• Explain LSTD 510 5-1 Interests Of The State  the Court’s use of “rational basis with bite” and its reasoning for rejecting irrational prejudice as a legitimate government interest.

The case involved a city ordinance that required a particular use permit for the operation of a group home for mentally disabled individuals. The Supreme Court applied the rational basis test but with a more scrutinizing approach, often referred to as “rational basis with bite.” The Court found that the city’s justifications for requiring a special permit from this group home. In contrast, other similar group homes for different categories of inhabitants did not need one and were not a legitimate interest (City of Cleburne v. Cleburne Living Center, 1985). The Court noted that irrational prejudice against the mentally disabled could not justify disparate treatment under the guise of a zoning ordinance.

Kadrmas v. Dickinson Public Schools, 487 US 450

• Describe the Court’s application of a standard rational basis review and the rationale behind upholding the transportation fee.

In Kadrmas, the Court upheld a North Dakota statute that allowed school districts to charge fees for transportation to school. The decision was based on a standard rational basis review. The Court found that the fee system was rationally related to the state’s interest in education and maintaining school budgets (Kadrmas v. Dickinson Public Schools, 1988). Unlike Plyler, where children’s access to education was outright denied, Kadrmas did not involve an outright denial but rather a condition that could potentially make access to education more difficult for some.

Do the local government’s interests in Cleburne seem rationally related to its decision to deny a permit for a home for the mentally retarded? Were the community’s concerns and fears truly legitimate interests? In Plyler, why didn’t the Court defer to Texas in its interest in discouraging illegal immigration? Why was the outcome in Kadrmas different than in Plyler?

ANALYSIS OF RATIONAL BASIS APPLICATION AND GOVERNMENT INTERESTS

City of Cleburne

• Evaluate LSTD 510 5-1 Interests Of The State whether community concerns were legitimate and rationally related to denying the permit.

The local government’s interests, purportedly based on community concerns about the “suitability” of the mentally disabled for the neighborhood, were deemed not rationally related to the discriminatory zoning practice. The Court discerned that these concerns were rooted more in irrational prejudice than in any legitimate municipal planning objective.

Plyler v. Doe

• Discuss why the Court did not defer to Texas’s interest and how the denial of education did not rationally further the state’s objective.

The Court did not defer to Texas’s interest in discouraging illegal immigration because the means chosen—denying education to children—was not appropriately related to the objective. The Court emphasized that the statute imposed a lifetime hardship on a discrete class of children not accountable for their illegal status, suggesting that the state’s purported interest in fiscal savings and discouraging immigration was not advanced rationally by the law.

Kadrmas v. Dickinson Public Schools

• Compare the outcome with Plyler, focusing on the fee’s impact versus outright denial of education.

The outcome differed from Plyler because the law did not outright deny a fundamental right but imposed a fee that, while potentially burdensome, did not preclude access to public education. The Court perceived this as a permissible local decision on resource allocation, not an unreasonable or wholly restrictive measure.

Is this test the best approach in trying to balance individual freedoms and government interests? Do any of the laws in these cases meaningfully advance the government’s goals?

EFFICACY OF THE RATIONAL BASIS TEST

• Analysis: Consider whether the LSTD 510 5-1 Interests Of The State  rational basis test protects individual rights while allowing for legitimate government actions.
• Case Laws: Evaluate if the laws in Plyler, Cleburne, and Kadrmas meaningfully advanced the stated government interests.

Example

While effective in allowing a broad exercise of governmental power, the rational basis test sometimes falls short in protecting individuals against laws that marginally advance a legitimate government interest. The test’s flexibility helped protect vulnerable populations in Plyler and Cleburne in the cases discussed. However, in Kadrmas, it allowed for a policy that could hinder access to education for less affluent children.

Why do you agree (or disagree) with the holdings in each case? Remember to support your answers and give attribution to your sources.

PERSONAL AGREEMENT WITH CASE HOLDINGS

• Plyler v. Doe: Explain LSTD 510 5-1 Interests Of The State your position on the Court’s decision and its protection of children’s rights.
• City of Cleburne v. Cleburne Living Center, Inc.: Justify your agreement or disagreement with the Court’s rejection of discriminatory zoning practices.
• Kadrmas v. Dickinson Pub. Schools: Provide reasons for your stance on the Court’s upholding of the transportation fee.

Example

I agree with the holdings in Plyler and Cleburne because both decisions appropriately scrutinized weak governmental interests that threatened to enforce prejudiced or economically punitive measures against vulnerable populations. However, I have reservations about Kadrmas, where the decision might be seen as underestimating the practical impact of the transportation fee on poorer families, potentially restricting their children’s access to education.

CLOSING

By following LSTD-510 5-1 Interests Of The State guidelines, you will be able to effectively analyze the application of the rational basis test in key Supreme Court cases, assess the balance between individual freedoms and government interests, and articulate your positions on the Court’s holdings.In the next module of  LSTD 510 5-2 LITERATURE REVIEW

REFERENCES 

City of Cleburne, Texas, et al., Petitioners v. Cleburne Living Center et al. (1985). LII / Legal Information Institute. https://www.law.cornell.edu/supremecourt/text/473/432

James plyler, Superintendent of the Tyler Independent School District and Its Board of Trustees et al., Appellants, v. J. and R. Doe et al. Texas, et al., Appellants, v. Certain named and unnamed undocumented alien children et al. (1982). LII / Legal Information Institute. https://www.law.cornell.edu/supremecourt/text/457/202

Paula Kadrmas, et al., Appellants v. Dickinson Public Schools et al. (1988). LII / Legal Information Institute. https://www.law.cornell.edu/supremecourt/text/487/450