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
The US Supreme Court found
that it did not deny the retirees equal protection as guaranteed by the 5th
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
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.