U.S. Railroad Retirement Board v. Fritz

SCOTUS- 1980

Facts

• Railroad Retirement Act restricted future accruals for windfall benefits by retired railroad workers.
• Grandfather provision retained benefits for some classes of individuals.
• This created lots of seemingly unfair issues with who got benefits.
• Appellee denied full windfall benefits.

Procedural History

• SD Indiana held the RRA unconstitutional.

Issues

• What standard of review should be applied to the RRA's provisions?

Holding/Rule

•   Rational basis applied.

Reasoning

• Congress could properly conclude that persons who had actually acquired statutory entitlement to windfalls while still employed had a greater equitable claim than the members of appellee's class, who were no longer in railroad employment when they became eligible.
• The "current connection" test is not a patently arbitrary means for determining which employees are "career railroaders" and the test has been used by Congress elsewhere.
• Where, as here, there are plausible reasons for Congress's action, our inquiry is at an end.

Dissent (Brennan)

• The Court fails to scrutinize the challenged classification in a manner established by our governing precedents.
• The mode f analysis used basically immunizes social and economic legislative classifications from judicial review.

• Rationalization is the product of gov't attorneys, and was not adopted by Congress. The actual purpose should be the basis for analysis.
• Rational basis is not a conceivable basis.

Notes

•  None.