Under rational basis review, Congress need not actually articulate the legitimate purpose or rationale that supports the classification at issue. Instead, a statute must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational basis for the classification.
Plaintiff city and officials and intervenors brought suit against defendants Secretary of Health and Human Services and other officers challenging provisions of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (the Act), that disqualified most legal aliens' eligibility for welfare benefits, alleging that the Act thus violated due process and equal protection.
Does the imposition of citizenship requirements for eligibility to welfare benefits violate equal protection and due process?
Concluding that the citizenship requirements of the Act did not offend equal protection, the court affirmed the district court's dismissal of plaintiffs' action. The court first determined that "rational basis" scrutiny, as opposed to strict or intermediate scrutiny, was appropriate, following precedent that state and federal alienage classifications must be treated differently because of Congress' plenary authority to regulate aliens. The court then held that the Act's provisions were rationally related to the legitimate governmental purpose of encouraging aliens' self sufficiency, and that the statute was not rendered irrational simply because it affected some aliens who were unable to work.