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New York City Transit Authority v. Beazer

    Citation. 440 U.S. 568, 99 S. Ct. 1355, 59 L. Ed. 2d 587, 1979 U.S. 77.

    Brief Fact Summary. A New York City Transit Authority rule barred the employment of persons who use narcotics. The Transit Authority applied the rule to all persons taking methadone – a drug widely used in the treatment of heroine addiction.

    Synopsis of Rule of Law. State legislation does not violate the Equal Protection Clause of the United States Constitution (Constitution) merely because the classifications that it makes are imperfect.


    Facts. A New York City Transit Authority rule barred the employment of persons who use narcotics. The Transit Authority applied the rule to persons taking methadone – a drug widely used in the treatment of heroine addiction. The District Court concluded that there were substantial numbers of methadone users who were just as employable as members of the general public and that the Transit Authority could have determined which users were not employable by resort to normal personnel screening procedures.

    Issue. Where a substantial number of methadone users were capable of performing jobs at the Transit Authority, does the Constitution permit the Transit Authority to make a blanket exclusion of all users from all jobs at the Transit Authority?

    Held. Yes. The Court of Appeals, affirming the District Court, is reversed.
    Justice John Paul Stevens stated that the assumptions upon which the Transit Authority’s rule are based concern matters of personnel policy that do not implicate the concerns the Equal Protection Clause of the Constitution are intended to protect. The Transit Authority’s rule serves the general objectives of safety and efficiency. The rule is not directed against any class of persons characterized by some unpopular trait. Therefore, it does not create the likelihood of bias on the part of the ruling majority.

    Dissent. Justice Byron White (J. White) said that the Transit Authority uses a rule that classifies fully employable methadone users as dispositively different from the general population without any justification. With the irrationality and invidiousness of the rule uncovered, it must fall as it violates the Equal Protection Clause of the Constitution.

    Discussion. This case calls into question what it means to treat two people equally under the Equal Protection Clause of the Constitution. What happens when providing equal treatment to two people will not result in equal treatment because the two people are not similarly situated? The “relevant difference” requirement holds that treating people differently can only be justified on the basis of differences between people relevant to the purpose of a rule.

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