Brief Fact Summary. Massachusetts law requires state police officers to retire upon turning 50 years old. The Respondent, Murgia (Respondent), argues that this compulsory retirement denies him equal protection under the laws.
Synopsis of Rule of Law. Age classifications are only subject to rational basis review.
Issue. May Massachusetts use an age classification to determine compulsory retirement of its police officers?
Held. Yes. Appeals Court ruling reversed.
The Supreme Court of the United State’s (Supreme Court) majority states that although there has been age discrimination in the past and at present, it does not represent the same type of “purposeful unequal treatment” that has been shown on the basis of race or national origin. As such, the Supreme Court states that rational basis review is the proper level of scrutiny in the current case.
Police work can be physically arduous and the individual officers must be capable of executing their duties fully in the interest of public safety. As individuals grow older, they are no longer as physically able as individuals in their 20’s and 30’s. Although Massachusetts requires routine physicals annually for all officers over the age of 40, there is no requirement that it base retirement solely on the results of these physicals. There is a rational basis for using a set age as a proxy, and hence, the Supreme Court finds no equal protection violation.
Perfection in making the necessary classifications is neither possible nor necessary.View Full Point of Law