New York City Transit Auth. v. Beazer, 440 U.S. 568 (1979)
A transit authority may choose to exclude all methadone users from consideration for employment.
Methadone is used to alleviate the physical aspects of heroin addiction. About a quarter of people who use methadone ultimately return to drug or alcohol abuse, but most people who use it for over a year no longer engage in illegal drug use. The New York Transit Authority, however, had a blanket policy against employing any methadone users. Individuals who had been terminated or denied employment with the Transit Authority on these grounds argued that the policy violated the Equal Protection Clause. They succeeded in the lower courts.Opinions
- John Paul Stevens (Author)
- Warren Earl Burger
- Potter Stewart
- Harry Andrew Blackmun
- William Hubbs Rehnquist
Many methadone users do not complete the program, and the record suggests that people who use methadone still are noticeably different in their behavior from people who do not use any drugs. It is unclear when a methadone user can be considered totally rehabilitated, so it would be difficult to enforce a more limited rule, such as a bar against methadone users who have been in the program for less than a year or a provision allocating methadone users to certain less dangerous jobs. Rational basis is the appropriate standard of review, and it is satisfied here because people who have completed the program can seek employment with the agency. Generally speaking, equal protection concerns do not apply to employment matters, even when they are broader than necessary. This rule also should be considered as part of the broader rule against employing drug users, which is clearly rational on its own.
- Byron Raymond White (Author)
- Thurgood Marshall
The policy fails rational basis review because it arbitrarily excludes successful methadone users who no longer engage in substance abuse. There is no apparent connection between participation in the methadone program and job performance. Other parts of the applicant evaluation process will allow the employer to screen employees who are unfit for the job based on their methadone use, and it appears that people who have participated in the program for a year are not meaningfully different from the general population. The agency does not have any policies that categorically exclude people with convictions, former alcoholics, mental patients, and diabetics, who are just as likely as methadone users to be unfit for employment.
- Lewis Franklin Powell, Jr. (Author)
- William Joseph Brennan, Jr. (Author)
The Court grappled with the logical problem of what to do when treating two people equally under a rule does not put them in an equally advantageous position because they are not similarly situated. Disparate treatment usually is appropriate only when the differences between the people are relevant to the purpose of the rule.
U.S. Supreme CourtNew York City Transit Auth. v. Beazer, 440 U.S. 568 (1979)
New York City Transit Authority v. Beazer
Argued December 6, 1978
Decided March 21, 1979
440 U.S. 568
Petitioner, New York City Transit Authority (TA), which, in operating the subway system and certain bus lines in New York City, employs about 47,000 persons, of whom many are employed in positions that involve danger to themselves or to the public, enforces a general policy against employing persons who use narcotic drugs. TA interprets its drug regulation to encompass current users of methadone, including those receiving methadone maintenance treatment for curing heroin addiction. Respondents, two former employees of TA who were dismissed while they were receiving methadone treatment, and two persons who were refused employment because they were receiving methadone treatment, brought a class action, alleging, inter alia, that TA's blanket exclusion of all former heroin addicts receiving methadone treatments was illegal under Title VII of the Civil Rights Act of 1964 and the Equal Protection Clause of the Fourteenth Amendment. The District Court found that TA's blanket methadone policy violates the Equal Protection Clause, and granted injunctive relief which, however, authorized TA to exclude methadone users from specific categories of safety-sensitive positions and also to condition eligibility on satisfactory performance in a methadone program for at least a year. Subsequently, the District Court also held that TA's drug policy violates Title VII because, even though the policy was not adopted with a discriminatory purpose, it nevertheless was not related to any of TA's business needs. The Court of Appeals affirmed the District Court's constitutional holding without reaching the statutory question.
1. An amendment to the Rehabilitation Act of 1973 after certiorari was granted, even if construed to proscribe TA's enforcement of a general rule denying employment to methadone users, does not render the case moot, since respondents' claims arose even before that Act itself was passed, and they have been awarded monetary relief. More importantly, however this Court might construe that Act, the concerns that prompted the grant of certiorari -- the lower courts' departure from the procedure normally followed in addressing statutory and constitutional questions in the same case, and the concern that those courts
erroneously decided the merits of such questions -- would still merit this Court's attention. Pp. 440 U. S. 580-581.
2. The statistical evidence on which respondents and the District Court relied does not support the conclusion that TA's regulation prohibiting the use of narcotics, or its interpretation of that regulation to encompass users of methadone, violated Title VII. Pp. 440 U. S. 583-587.
(a) The statistic that 81% of the employees referred to TA's medical director for suspected violations of its narcotics rule were either black or Hispanic indicates nothing about the racial composition of the employees suspected of using methadone, and respondents have only challenged the rule to the extent that it is construed to apply to methadone users. Nor does the record provide any information about the number of black, Hispanic, or white persons who were dismissed for using methadone. Pp. 440 U. S. 584-585.
(b) The statistic that about 63% of the persons in New York City receiving methadone maintenance in public programs are black or Hispanic does not indicate how many of these persons ever worked or sought to work for TA; tells nothing about the class of otherwise qualified applicants and employees who have participated in methadone maintenance programs for over a year, the only class improperly excluded by TA's policy under the District Court's analysis; and affords no data on the 14,000 methadone users in private programs, leaving open the possibility that the percentage of blacks and Hispanics in the class of methadone users is not significantly greater than the percentage of those minorities in the general population of New York City. Pp. 440 U. S. 585-586.
(c) Even if respondents' statistical showing is considered to be sufficient to establish a prima facie case of discrimination, it is rebutted by TA's demonstration that its narcotics rule (and the rule's application to methadone users) is "job-related." The District Court's finding that the rule was not motivated by racial animus forecloses any claim that it was merely a pretext for intentional discrimination. P. 587.
3. TA's blanket exclusion of persons who regularly use narcotic drugs, including methadone, does not violate the Equal Protection Clause for failing to include more precise special rules for methadone users who have progressed satisfactorily with their treatment for one year and who, when examined individually, satisfy TA's employment criteria for nonsensitive jobs. Pp. 440 U. S. 587-594.
(a) An employment policy such as TA's that postpones eligibility for employment until the methadone treatment has been completed, rather than accepting an intermediate point on an uncertain line -- such as one year of treatment -- is rational, and is neither unprincipled nor
invidious in the sense that it implies disrespect for the excluded subclass. Pp. 440 U. S. 590-592.
(b) Even assuming that TA's rule is broader than necessary to exclude those methadone users who are not actually qualified to work for TA, and that it is probably unwise for a large employer like TA to rely on a general rule, instead of individualized considerations of every job applicant, nevertheless, under the circumstances of this case, such assumptions concern matters of personnel policy that do not implicate the principle safeguarded by the Equal Protection Clause. Pp. 440 U. S. 592-593.
558 F.2d 97, reversed.
STEVENS, J., delivered the opinion of the Court, in which BURGER, C.J., and STEWART, BLACKMUN, and REHNQUIST, JJ., joined. POWELL, J., filed an opinion concurring in part and dissenting in part, post, p. 440 U. S. 594. BRENNAN, J., filed a dissenting statement, post, p. 440 U. S. 597. WHITE, J., filed a dissenting opinion, in which MARSHALL, J., joined, post, p. 440 U. S. 597.