New York City Transit Authority v. Beazer
440 U.S. 568 (1979)

  • NYCTA had a blanket rule that they would not employ anyone found to be using narcotics.
    • They included in that definition anyone who was taking methadone as a treatment for heroin addiction.
  • Beazer and another guy were fired for taking methadone and sued.
  • The Trial Court found the rule to be an unconstitutional violation of the Equal Protection Clause of the 14th Amendment. NYCTA appealed.
  • The Appellate Court affirmed. NYCTA appealed.
  • The US Supreme Court reversed and found the rule to be constitutional.
    • The US Supreme Court found that the NYCTA had a rational basis for its classification of narcotics users and the extension of this rule to cover methadone users was permissible.
    • Beazer unsuccessfully argued that the rule was overinclusive. While there was good reason for not wanting drug addicts driving subway trains, it shouldn’t include people who were in treatment and were working in desk jobs unconnected to safety.
      • The Court noted that it was probably unwise for NYCTA to rely on a blanket rule instead of considering everyone on a case-by-case basis, but that was NYCTA’s problem, it wasn’t a constitutional issue.
  • Basically, this case said that if there is a legitimate purpose (in this case train safety), it is constitutional permissible to write a law that goes above and beyond the minimum necessary to accomplish the goal, even if that ends up hurting people.