rational basis test in Maine

2023E.g., Califano v. Aznavorian, 439 U.S. 170, 174, 178 (1978).

2023E.g., Califano v. Aznavorian, 439 U.S. 170, 174, 178 (1978).

2023See Doe v. Williams, 2013 ME 24 , ,r 65, 61 A.3d 718 . 5 When considering the constitutionality of social welfare legislation under the federal Constitution, courts apply the rational basis test.

2023See Doe v. Williams, 2013 ME 24 , ,r 65, 61 A.3d 718 . 5 When considering the constitutionality of social welfare legislation under the federal Constitution, courts apply the rational basis test.

1999See 30-A M.R.S.A. § 5405(1). [¶ 12] The rental agencies rely on an equal protection case, McNicholas v. York Beach Village Corp., 394 A.2d 264 (Me.1978), for their assertion that the fee is unreasonable because it treats users of the airport differently and would not survive a rational basis analysis.

1981The law need not operate uniformly on all individuals “as long as those affected are reasonably different from those excluded and there is a rational basis for treating them differently.” Nadeau, 395 A.2d at 113 ; McNicholas v. York Village Corp., Me., 394 A.2d 264, 269 (1978).

2006Under the rational basis standard, the burden is on the party challenging the government action to demonstrate that “there exists no fairly conceivable set of facts that could ground a rational relationship between the challenged classification and the government’s legitimate goals.” Eulitt, 386 F.3d at 356 . [¶30] In Bagley , we did not address which level of scrutiny should be applied in analyzing whether section 2951(2) violated the Equal Protection Clause.

2006See id Under the rational basis standard, the burden is on the party challenging the government action to demonstrate that "there exists no fairly conceivable set of facts that could ground a rational relationship between the challenged classification and the government's legitimate goals." Eulitt [v. State of Me., Dep 't of Educ., 386 F.3d 344, 356 (1st Cir. 2004)].

2006See id.

2006See id.

2025See Jacobson v. Commonwealth of Massachusetts, 197 U.S. 11 (1905) (applying a rational-basis analysis to determine whether a state vaccine requirement was constitutional); Pitts v. Moore, 2014 ME 59 , ¶ 12 & n.3, 90 A.3d 1169 (setting forth the strict-scrutiny standard requiring a compelling government interest for the government to interfere with the fundamental right to parent).

2023See Beaulieu v. Lewiston, 440 A.2d 334, 339 (Me. 1982) ('"the Equal Protection Clause does not require that a State must choose between attacking every aspect of a problem or not attacking the problem at all"').

2020Judicial review of whether legislation serves a public purpose is made pursuant to the rational basis test and court’s will not consider the legislation’s “wisdom or efficacy as a matter of economic or fiscal policy.” Common Cause v. State, 455 A.2d 1, 25 (Me. 1983).

2020“The weighing of [the legislation’s] costs and benefits is for the Legislature in the first instance . . . .” Id.

2016Courts applying the rational basis standard will not set aside even a discriminatory statutory scheme if "any state of facts reasonably may be conceived to justify it" Bowen v. Gilliard, 483 U.S. 587, 600-01 (198'7) (internal citation omitted).

2012See Smith v. Shalala, 5 F.3d 235, 239 (7th Cir. 1993) (in the absence of interference with a fundamental right, classification based on marital status analyzed under the rational basis test).

2008"A statute runs afoul of the Due Process Clause only if it `manifests a patently arbitrary classification, utterly lacking in rational justification.'" United States v. Neal, 46 F.3d 1405, 1409 (7th Cir.1995) (quoting Weinberger v. Salfi, 422 U.S. 749, 768 , 95 S.Ct. 2457 , 45 L.Ed.2d 522 (1975)). "[T]he statute's justification need not be expressly articulated or readily apparent `so long as a court can divine some rational purpose.'" *430 Id. (quoting United States v. Cyrus, 890 F.2d 1245, 1248 (D.C.Cir.1989)). [¶ 15] The jurisdictional prerequisite of the post-conviction statute, 15 M.R.S.

2008“A statute runs afoul of the Due Process Clause only if it ‘manifests a patently arbitrary classification, utterly lacking in rational justification.’ ” United States v. Neal, 46 F.3d 1405, 1409 (7th Cir.1995) (quoting Weinberger v. Salfi, 422 U.S. 749, 768 , 95 S.Ct. 2457 , 45 L.Ed.2d 522 (1975)). “[T]he statute’s justification need not be expressly articulated or readily apparent ‘so long as a court can divine some rational purpose.’ ” Id. (quoting United States v. Cyrus, 890 F.2d 1245, 1248 (D.C.Cir.1989)). [¶ 15] The jurisdictional prerequisite of the post-conviction statute, 15 M.R.S. § 2

2008Constitutionality of the Post-conviction Review Statute's Jurisdictional Prerequisite [¶ 12] Ngo argues that if the jurisdictional prerequisite of the post-conviction review statute does not allow him to maintain a cause of action for post-conviction review, then the statute is unconstitutionally arbitrary as applied to him. [¶ 13] The right to post-conviction review is not a fundamental right and thus, the statute is constitutional if it is rationally related to the government's interest. [4] See Washington v. Glucksberg, 521 U.S. 702, 728 , 117 S.Ct. 2258 , 138 L.Ed.2d 772 (1997); PFZ Props.

2008Constitutionality of the Post-conviction Review Statute’s Jurisdictional Prerequisite [¶ 12] Ngo argues that if the jurisdictional prerequisite of the post-conviction review statute does not allow him to maintain a cause of action for post-conviction review, then the statute is unconstitutionally arbitrary as applied to him. [¶ 13] The right to post-conviction review is not a fundamental right and thus, the statute is constitutional if it is rationally related to the government’s interest. 4 See Washington v. Glucksberg, 521 U.S. 702, 728 , 117 S.Ct. 2258 , 138 L.Ed.2d 772 (1997); PFZ Props.,

2008"A statute runs afoul of the Due Process Clause only if it `manifests a patently arbitrary classification, utterly lacking in rational justification.'" United States v. Neal, 46 F.3d 1405, 1409 (7th Cir.1995) (quoting Weinberger v. Salfi, 422 U.S. 749, 768 , 95 S.Ct. 2457 , 45 L.Ed.2d 522 (1975)). "[T]he statute's justification need not be expressly articulated or readily apparent `so long as a court can divine some rational purpose.'" *430 Id. (quoting United States v. Cyrus, 890 F.2d 1245, 1248 (D.C.Cir.1989)). [¶ 15] The jurisdictional prerequisite of the post-conviction statute, 15 M.R.S.

2008“A statute runs afoul of the Due Process Clause only if it ‘manifests a patently arbitrary classification, utterly lacking in rational justification.’ ” United States v. Neal, 46 F.3d 1405, 1409 (7th Cir.1995) (quoting Weinberger v. Salfi, 422 U.S. 749, 768 , 95 S.Ct. 2457 , 45 L.Ed.2d 522 (1975)). “[T]he statute’s justification need not be expressly articulated or readily apparent ‘so long as a court can divine some rational purpose.’ ” Id. (quoting United States v. Cyrus, 890 F.2d 1245, 1248 (D.C.Cir.1989)). [¶ 15] The jurisdictional prerequisite of the post-conviction statute, 15 M.R.S. § 2

2008Constitutionality of the Post-conviction Review Statute's Jurisdictional Prerequisite [¶ 12] Ngo argues that if the jurisdictional prerequisite of the post-conviction review statute does not allow him to maintain a cause of action for post-conviction review, then the statute is unconstitutionally arbitrary as applied to him. [¶ 13] The right to post-conviction review is not a fundamental right and thus, the statute is constitutional if it is rationally related to the government's interest. [4] See Washington v. Glucksberg, 521 U.S. 702, 728 , 117 S.Ct. 2258 , 138 L.Ed.2d 772 (1997); PFZ Props.

2008Constitutionality of the Post-conviction Review Statute’s Jurisdictional Prerequisite [¶ 12] Ngo argues that if the jurisdictional prerequisite of the post-conviction review statute does not allow him to maintain a cause of action for post-conviction review, then the statute is unconstitutionally arbitrary as applied to him. [¶ 13] The right to post-conviction review is not a fundamental right and thus, the statute is constitutional if it is rationally related to the government’s interest. 4 See Washington v. Glucksberg, 521 U.S. 702, 728 , 117 S.Ct. 2258 , 138 L.Ed.2d 772 (1997); PFZ Props.,

2006See Locke v. Davey, 540 U.S. 712, 719 , 124 S.Ct. 1307 , 158 L.Ed.2d 1 (2004) (citing Zelman, 536 U.S. at 652 , 122 S.Ct. 2460 ). [¶ 70] Relying on Locke , a United States Supreme Court case decided subsequent to Zelman , this Court concludes that, although it is clear that Maine could repeal section 2951(2) and again make section 5204(4) neutral as to religion, as it once was, and could reinstate tuition aid to parents who reside in towns without public schools and who choose to send their children to sectarian schools without violating the Establishment Clause, the elimination of the discrim

2006See Locke v. Davey, 540 U.S. 712, 719 , 124 S.Ct. 1307 , 158 L.Ed.2d 1 (2004) (citing Zelman, 536 U.S. at 652 , 122 S.Ct. 2460 ). [¶ 70] Relying on Locke , a United States Supreme Court case decided subsequent to Zelman , this Court concludes that, although it is clear that Maine could repeal section 2951(2) and again make section 5204(4) neutral as to religion, as it once was, and could reinstate tuition aid to parents who reside in towns without public schools and who choose to send their children to sectarian schools without violating the Establishment Clause, the elimination of the discrim

2006The rational basis standard is highly deferential and we hold legislative acts unconstitutional under a rational basis standard in only the most exceptional circumstances." Doe v. Moore, 410 F.3d at 1345 (quotations and citation omitted).

2006See Locke v. Davey, 540 U.S. 712, 719 , 124 S.Ct. 1307 , 158 L.Ed.2d 1 (2004) (citing Zelman, 536 U.S. at 652 , 122 S.Ct. 2460 ). [¶ 70] Relying on Locke , a United States Supreme Court case decided subsequent to Zelman , this Court concludes that, although it is clear that Maine could repeal section 2951(2) and again make section 5204(4) neutral as to religion, as it once was, and could reinstate tuition aid to parents who reside in towns without public schools and who choose to send their children to sectarian schools without violating the Establishment Clause, the elimination of the discrim

2006See Locke v. Davey, 540 U.S. 712, 719 , 124 S.Ct. 1307 , 158 L.Ed.2d 1 (2004) (citing Zelman, 536 U.S. at 652 , 122 S.Ct. 2460 ). [¶ 70] Relying on Locke , a United States Supreme Court case decided subsequent to Zelman , this Court concludes that, although it is clear that Maine could repeal section 2951(2) and again make section 5204(4) neutral as to religion, as it once was, and could reinstate tuition aid to parents who reside in towns without public schools and who choose to send their children to sectarian schools without violating the Establishment Clause, the elimination of the discrim