LSTD 510 5-1 INTERESTS OF THE STATE

LSTD 510 5-1 Interests Of The State assignment of This Owlisdom investigates the rational basis test, a standard of judicial review that is used to analyze the constitutionality of laws that impact upon constitutional rights and are not deemed to be of fundamental right nor a protected class. By analyzing three key supreme court cases, you will discover how the test is used, if it empowers individual freedoms and government interests adequately.

• Give an introduction

Example

Rational basis test is the most relaxed form of the judicial review sought by courts in the assessment of legislation that infringe on constitutional liberties. The test is used when a plaintiff is not seeking to vindicate a fundamental right under Article III or alleging membership in a protected class under the Fourteenth Amendment. Being the least demanding criterion, it demands that a law bear a rational relationship to a 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).

• The LSTD 510 5 1 Interests Of The State Court’s decision to strike down of a Texas statute that denied school funding to children born of illegal immigrants is examined.

• City of Cleburne v. Cleburne Living Center, Inc.: Judge the city’s ruling of the ordinance requiring a special permit for a group home for mentally disabled people.

• Kadrmas v. Dickinson Pub. Schools: Look at the Court’s decision to uphold a North Dakota statute allowing school districts to levy 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

• Why did the Court apply a more exacting version of the rational basis test when dealing with the vulnerable status of children in LSTD 510 5 1 interests of the state.

In Plyler v. In January 1982, the Supreme Court declared unconstitutional a Texas statute, struck down by the Court in 1979, which deprived of an education illegally residing children. Because it involved children—vulnerable individuals—whose condition as illegal immigrants is the result not of their own making, the Court applied a more exacting version of the rational basis test (Plyler v. Doe). Doe, 1982). The Court then concluded that ■ ■ denying these children an education would not, logically speaking, further the state’s interest in limiting illegal immigration or reducing costs because ■ ■ the long term costs of under educating these children would far outweigh the savings the statute would make for the government concerning the cost of educating these children.

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

• Briefly explain LSTD 510 5-1 Interests Of The State The Court’s use of “rational basis with bite” and why it concluded that irrational prejudice is not an acceptable state interest.

A city ordinance which would have required a particular use permit for the operation of a group home for mentally disabled individuals was at issue in the case. In place of the rational basis test, the Supreme Court used the “rational basis with bite,” applying it, however, under a stricter standard. The city had justifications for needing a special permit from this group home, it found the Court. Unlike other similar group homes for other categories of inhabitants, it did not require one and was not a legitimate interest (City of Cleburne v. History: Michigan Native American Artist Twins (Cleburne Living Center, 1985). Under the cloak of a zoning ordinance there could be no justification for disparate treatment based on irrational prejudice against the mentally disabled as the Court found..

Kadrmas v. Dickinson Public Schools, 487 US 450

• It explains how a standard rational basis review was used by the Court to defend the transportation fee.

The Court upheld, in Kadrmas, a North Dakota statute that permitted a school district to charge a fee for transportation to school.. It was a standard rational basis review that was used as the decision. Kadrmas v. Dickinson, the court found that the fee system was rationally related to that interest in education, preserving the budget of the schools. August 1, 1988, Dickinson Public Schools).Unlike Plyler the access of children to education was not outright denied, while Kadrmas did not deny access outright, it did impose a condition that would not necessarily hinder access to education but could potentially have that effect 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

• Determine LSTD 510 5 1 Interests Of The State rationally whether community interests were legitimate for the permit’s denials.

The Court held that, even if that rationale purportedly represented the local government’s interest in furthering the local community’s interest in maintaining the neighborhood “suitability” of the mentally disabled, it was not rationally related to the discriminatory zoning. Although the Court noted that these concerns were not connected to any legitimate municipal planning objective, it found that they were grounded instead upon irrational prejudice.

Plyler v. Doe

• Explain why the Court did not defer to th Texas interest and why denial of education failed to rationally further the state objective.

Because the chosen means, denying education to children, was not an appropriate way of advancing Texas’s interest in discouraging illegal immigration, the Court did not defer to Texas’s interest. The Court reasoned that the statute’s imposition of a lifetime hardship on a discrete class of children not reasonably contemplated to be accountable for their actions, made no rational connection to further governmental objective and fell outside the scope of legitimate state interest to exclude aliens, such as fear of economic dependency on them.

Kadrmas v. Dickinson Public Schools

• Compare your result to Plyler, where the correlation lies between the fee and outright denial of education.

This was different than in Plyler because the law was not one that flatly took away a fundamental right, but rather set a fee that could be burdensome but that did not prevent access to public education.. The Court saw it as a decision they believed was reasonable on allocational grounds for resource allocation within local bounds.

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

• Ask yourself if an application of the LSTD 510 5-1 Interests Of The State rational basis test is safe for individual rights and allows operative government activities.

  Case Laws: Assess whether the Plyler, Cleburne, and Kadrmas laws amounted to a ‘meaningful advance’ of those government interests.

Example

The rational basis test is effective in authorizing a wide exercise of governmental power, but it is not necessarily effective in preventing the government from passing a law that marginally advances a legitimate government interest from infringing upon an individual’s rights.In the cases covered, the test’s flexibility helped preserve vulnerable populations in Plyler and Cleburne.But in Kadrmas, it enabled a policy that could close off access to education for children less able to afford it.

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: Give your view on what the Court’s decision and adoption of such policy means in terms protection of the rights of children.

• City of Cleburne v. Cleburne Living Center, Inc.: Explain why you agreed or disagreed with the Court’s rejection of discriminatory zoning principles.Kadrmas v. Dickinson Pub. Schools: Why do you stand for upholding of the transportation fee?

Example

Both Plyler and Cleburne, I believe, correctly subjected superficial governmental interests from being the basis for prejudicial or economically punitive measures directed at vulnerable groups. But I have concerns about Kadrmas, in that the decision may be seen as ignoring the real effects of transportation on poorer families spending for their children’s education

CLOSING

Follow LSTD-510 5-1 Interests Of The Stateguidelines and you will be able to effectively analyze the application of the rational basis test in key Supreme Court cases, balance individual freedoms against government interests, and articulate your positions on the Court’s holdings in 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