New York City Transit Authority v. Beazer | |
---|---|
Argued December 6, 1978 Decided March 21, 1979 | |
Full case name | New York City Transit Authority, et al. v. Carla A. Beazer, et al. |
Citations | 440 U.S. 568 ( more ) 99 S. Ct. 1355; 59 L. Ed. 2d 587; 1979 U.S. LEXIS 77; 19 Fair Empl. Prac. Cas. (BNA) 149; 19 Empl. Prac. Dec. (CCH) ¶ 9027; 1 Am. Disabilities Cas. (BNA) 73 |
Case history | |
Prior | Beazer v. New York City Transit Authority, 399 F. Supp. 1032 (S.D.N.Y.), aff'd, 558 F.2d 97 (2nd Cir. 1976), cert. granted, 440 U.S. 568(1978). |
Subsequent | None |
Holding | |
The NYC Transit Authority had a rational basis for its classification of narcotics users and by extension, methadone users. | |
Court membership | |
| |
Case opinions | |
Majority | Stevens, joined by Burger, Stewart, Blackmun, Rehnquist |
Concur/dissent | Powell |
Dissent | Brennan |
Dissent | White, joined by Marshall |
Laws applied | |
U.S. Const. Amend. XIV, Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e |
New York City Transit Authority v. Beazer, 440 U.S. 568 (1979), was a case decided by the United States Supreme Court in which the constitutionality of an employer's refusal to hire methadone users was upheld.
The New York City Transit Authority (NYCTA) adopted a rule prohibiting the employment of anyone who used narcotic drugs. This rule was applied to persons using methadone, a drug used to treat heroin addiction. Two former NYCTA employees who had been fired while receiving methadone treatment and two applicants who were denied employment because of their use and past use of methadone sued the TA in federal district court.
The court for the Southern District of New York ruled in favor of the plaintiffs and found the policy unconstitutional. While the district court enjoined the NYCTA from denying employment solely on the basis of past or current participation in a methadone maintenance program, it did authorize the transit authority to exclude methadone users from certain safety-related positions, as well as to condition employment on satisfactory performance in a methadone program for at least one year. This decision was affirmed by the Court of Appeals for the Second Circuit.
The Court was confronted with the question of whether a government could choose not to employ, as an entire class, users of narcotic drugs.
The Court, in an opinion delivered by Justice Stevens, reversed the decision of the lower courts and found that the NYC Transit Authority had a rational basis for its classification of narcotics users and the extension of this rule to cover methadone users.
Justices Brennan and White wrote separate dissents. Justice Brennan dissented on the grounds that the Title VII claim had been proven. Justice White, joined by Justice Marshall, argued that the classification of persons successfully participating in a methadone program as dispositively different from the general population was without justification. They believed that this classification violated the equal protection clause as irrational and invidious.
The New York City Transit Authority is a public-benefit corporation in the U.S. state of New York that operates public transportation in New York City. Part of the Metropolitan Transportation Authority, the busiest and largest transit system in North America, the NYCTA has a daily ridership of 8 million trips.
William Joseph Brennan Jr. was an American lawyer and jurist who served as an Associate Justice of the United States Supreme Court from 1956 to 1990. He was the seventh-longest-serving justice in Supreme Court history, and known for being a leader of the Court's liberal wing.
Craig v. Boren, 429 U.S. 190 (1976), was a landmark decision of the US Supreme Court ruling that statutory or administrative sex classifications were subject to intermediate scrutiny under the Fourteenth Amendment's Equal Protection Clause.
Robinson v. California, 370 U.S. 660 (1962), is the first landmark decision of the United States Supreme Court in which the Eighth Amendment of the Constitution was interpreted to prohibit criminalization of particular acts or conduct, as contrasted with prohibiting the use of a particular form of punishment for a crime. In Robinson, the Court struck down a California law that criminalized being addicted to narcotics.
Eisenstadt v. Baird, 405 U.S. 438 (1972), was a landmark decision of the US Supreme Court that established the right of unmarried people to possess contraception on the same basis as married couples.
Illinois v. Gates, 462 U.S. 213 (1983), is a Fourth Amendment case. Gates overruled Aguilar v. Texas and Spinelli v. United States, thereby replacing the Aguilar–Spinelli test for probable cause with the "totality of the circumstances" test.
National Treasury Employees Union v. Von Raab, 489 U.S. 656 (1989), was a United States Supreme Court case involving the Fourth Amendment and its implication on drug testing programs. The majority of the Court upheld the drug testing program in United States Customs Service.
Agostini v. Felton, 521 U.S. 203 (1997), is a landmark decision of the Supreme Court of the United States. In this case, the Court overruled its decision in Aguilar v. Felton (1985), now finding that it was not a violation of the Establishment Clause of the First Amendment for a state-sponsored education initiative to allow public school teachers to instruct at religious schools, so long as the material was secular and neutral in nature and no "excessive entanglement" between government and religion was apparent. This case is noteworthy in a broader sense as a sign of evolving judicial standards surrounding the First Amendment, and the changes that have occurred in modern Establishment Clause jurisprudence.
Geduldig v. Aiello, 417 U.S. 484 (1974), was an equal protection case in the United States in which the Supreme Court of the United States ruled on whether unfavorable treatment to pregnant women could count as sex discrimination. It held that the denial of insurance benefits for work loss resulting from a normal pregnancy did not violate the Fourteenth Amendment. The California insurance program at issue did not exclude workers from eligibility based on sex but excluded pregnancy from a list of compensable disabilities. The majority found that even though only women would be directly affected by the administrative decision, the classification of normal pregnancy as non-compensable was not a sex-based classification and so the court would defer to the state so long as it could provide a rational basis for its categorization.
Lyng v. Castillo, 477 U.S. 635 (1986), reversed a lower court's decision that the change in the statutory definition of a household violated the appellee's due process rights. The program rules for food stamps were changed in 1981 and 1982 which changed the definitions of households. The Supreme Court of the United States ruled that the District Court erred in using heightened scrutiny to analyze the validity of the household definition.
Department of Agriculture v. Moreno, 413 U.S. 528 (1973), was a United States Supreme Court case that declared a provision of the Food Stamp Act denying food stamps to households of "unrelated persons" to be a violation of the U.S. Constitution. The Court held that provision to be irrelevant to the stated purpose of the statute and in violation of the Due Process Clause of the Fifth Amendment.
Quantity of Books v. Kansas, 378 U.S. 205 (1964), is an in rem United States Supreme Court decision on First Amendment questions relating to the forfeiture of obscene material. By a 7–2 margin, the Court held that a seizure of the books was unconstitutional, since no hearing had been held on whether the books were obscene, and it reversed a Kansas Supreme Court decision that upheld the seizure.
Jackson v. Metropolitan Edison Co., 419 U.S. 345 (1974), is an administrative law case of the Supreme Court of the United States holding that extensive state regulation of a public utility does not transform its acts into state action that is reviewable by a federal court under the Fourteenth Amendment to the United States Constitution.
Rutan v. Republican Party of Illinois, 497 U.S. 62 (1990), was a United States Supreme Court decision that held that the First Amendment forbids a government entity from basing its decision to promote, transfer, recall, or hire low-level public employees based upon their party affiliation.
Schuette v. Coalition to Defend Affirmative Action, 572 U.S. 291 (2014), was a landmark decision of the Supreme Court of the United States concerning affirmative action and race- and sex-based discrimination in public university admissions. In a 6-2 decision, the Court held that the Fourteenth Amendment's Equal Protection Clause does not prevent states from enacting bans on affirmative action in education.
Times Film Corporation v. City of Chicago, or Times v. City of Chicago is the name of two cases decided by the U.S. Supreme Court in 1957 and 1961. Both involved the issue of limits on freedom of expression in connection with motion pictures. In both cases the court affirmed the right of local governments to engage in some form of censorship.
Califano v. Goldfarb, 430 U.S. 199 (1977), was a decision by the United States Supreme Court, which held that the different treatment of men and women mandated by 42 U.S.C. § 402(f)(1)(D) constituted invidious discrimination against female wage earners by affording them less protection for their surviving spouses than is provided to male employees, and therefore violated the Due Process Clause of the Fifth Amendment to the United States Constitution. The case was brought by a widower who was denied survivor benefits on the grounds that he had not been receiving at least one-half support from his wife when she died. Justice Brennan delivered the opinion of the court, ruling unconstitutional the provision of the Social Security Act which set forth a gender-based distinction between widows and widowers, whereby Social Security Act survivors benefits were payable to a widower only if he was receiving at least half of his support from his late wife, while such benefits based on the earnings of a deceased husband were payable to his widow regardless of dependency. The Court found that this distinction deprived female wage earners of the same protection that a similarly situated male worker would have received, violating due process and equal protection.
Henderson v. United States, 568 U.S. 266 (2013), was a United States Supreme Court case in which the Court held regardless of whether a legal question was settled or unsettled at the time of trial, an error is "plain" within the meaning of Rule 52(b) of Federal Rule of Criminal Procedure so long as the error was plain at the time of appellate review.
Bostock v. Clayton County, 590 U.S. ___ (2020), was a landmark United States Supreme Court civil rights case in which the Court held that Title VII of the Civil Rights Act of 1964 protects employees against discrimination because they are gay or transgender.
Lehman v. City of Shaker Heights, 418 U.S. 298 (1974), was a case in which the United States Supreme Court upheld a city's ban on political advertising within its public transportation system. The Court ruled that ad space on public transit is not a "public forum", meaning that speech within this space receives lower First Amendment protections.