Federal Communications Commission v. Beach Communications, Inc.

Citation. 508 U.S. 307, 113 S.Ct. 2096, 124, L.Ed.2d 211 (1993).

Brief Fact Summary.

Plaintiff challenged an FCC ruling on satellites and won in the lower circuit court.

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Synopsis of Rule of Law.

When there is a conceivable rational basis for differential treatment between classes and it does not implicate a suspect classification or infringe on a fundamental right, the law will not be invalidated on constitutional grounds.

Facts.

Plaintiff operated satellite television systems that serviced multiple unit dwellings owned by multiple parties. The Commission ruled that satellite systems serving multiple unit dwellings owned by multiple parties, including the ones owned by the Plaintiff, were subject to additional federal regulations. Multiple dwelling units under common ownership, however, were not subject to the regulations. Plaintiff brought suit challenging the constitutionality of the FCC ruling.

Issue.

Whether the exemption for common ownership systems violates the equal protection guarantees of the 14th Amendment.

Held.

No. The exemption for common ownership systems does not violate the equal protection guarantees of the 14th Amendment.

Concurrence.

Justice Stevens

While I am not fully persuaded that the common ownership exemption is justified, it is reasonable to presume that Congress was motivated by an interest in allowing property owners to exercise freedom in the use of their own property. Legislation so motivated surely does not violate the sovereign’s duty to govern impartially.

Discussion.

Whether embodied in the 14th Amendment or inferred from the Fifth, equal protection is not a license for courts to judge the wisdom, fairness, or logic of legislative choices. In areas of social and economic policy, a statutory classification that neither proceeds along suspect lines nor infringes fundamental constitutional rights must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational basis for the classification.

Applying these principles, we conclude the common ownership distinction is constitutional. Judgement reversed.