The Equal Protection Clause of the Fourteenth Amendment provides that no state shall deny to any person within its jurisdiction the equal protection of the laws. The clause announces a fundamental principle: the state must govern impartially. General rules that apply evenhandedly to all persons within the jurisdiction unquestionably comply with this principle. Only when a governmental unit adopts a rule that has a special impact on less than all the persons subject to its jurisdiction does the question whether this principle is violated arise.
This litigation was brought by respondents as a class action on behalf of all persons who had been or would in the future be subject to discharge or rejection as employees of the public employer, a transit authority, by reason of participation in a methadone maintenance program. Their complaint alleged that the employer's blanket exclusion of all former heroin addicts receiving methadone treatment was illegal under Title VII of the Civil Rights Act of 1964 (Title VII), 42 U.S.C.S. § 2000e et seq., and the Equal Protection Clause of the Fourteenth Amendment. The district court held that the policy was unconstitutional, and the United States Court of Appeals for the Second Circuit affirmed. The employer then filed a petition for certiorari, which was granted.
Was the employment policy violative of the equal protection clause of Fourteenth Amendment?
The court held that as the rule was not motivated by racial animus, there was no rebuttal claim that it was merely a pretext for intentional discrimination, and the findings did not support the conclusion that the regulation prohibiting the use of narcotics violated Title VII. While it may have been unwise for the employer to rely on a general rule instead of individualized consideration of every job applicant, it concerned matters of personnel policy that did not violate equal protection principles, and the Constitution did not authorize a federal court to interfere in such policy decisions.