United States Railroad Retirement Board v. Fritz
449 U.S. 166 (1980)

  • Congress passed the Railroad Retirement Act, which restructured the railroad retirement system.
    • Up until that time, railroad workers’ retirement benefits were calculated under a different system than Social Security, and there were loopholes whereby people who had worked for a railroad and also worked elsewhere could double-dip.
      • The Railroad Retirement Act was very complicated, but was enacted to stop the double-dipping.
  • The law was pretty Byzantine, and there were certain groups of workers that lost benefits under the new system. They sued.
    • The workers felt that the law had some pretty arbitrary provisions. For example, it made divisions of employees based on whether they were ‘active’ in the railroad industry at the time the law was passed.
      • The workers argued that this was not “rationally related” to the congressional purposes of insuring the solvency of the railroad retirement system and protecting vested benefits.
  • The US Supreme Court found the Railroad Retirement Act to be constitutional
    • The US Supreme Court found that it did not deny the retirees equal protection as guaranteed by the 5th Amendment.
    • The Court found that to withstand judicial scrutiny on equal protection grounds, a law must bear a rational relation to some legitimate end.
      • That’s the rational basis test.
    • In this case, the law itself was seemingly irrational and arbitrary. However, the Court found that since the law was conceivably designed to have a legitimate purpose, it didn’t matter if the law’s actual effect furthered that purpose.
  • In a dissent, it was argued that a conceivable legitimate purpose is not sufficient, and that an actual legitimate purpose is required.