rational basis test in Washington

2007We disagree. ¶ 55 Washington courts review equal protection challenges to the SVP Act under the rational basis test. [18] In re Turay, 139 Wash.2d 379, 409-10 , 986 P.2d 790 (1999), cert. denied, 531 U.S. 1125 , 121 S.Ct. 880 , 148 L.Ed.2d 789 (2001).

2007We disagree. ¶55 Washington courts review equal protection challenges to the SVP act under the rational basis test. 18 In re Det. of Turay, 139 Wn.2d 379, 409-10 , 986 P.2d 790 (1999), cert. denied, 531 U.S. 1125 (2001).

2007We disagree. ¶ 55 Washington courts review equal protection challenges to the SVP Act under the rational basis test. [18] In re Turay, 139 Wash.2d 379, 409-10 , 986 P.2d 790 (1999), cert. denied, 531 U.S. 1125 , 121 S.Ct. 880 , 148 L.Ed.2d 789 (2001).

2007We disagree. ¶55 Washington courts review equal protection challenges to the SVP act under the rational basis test. 18 In re Det. of Turay, 139 Wn.2d 379, 409-10 , 986 P.2d 790 (1999), cert. denied, 531 U.S. 1125 (2001).

2016The rational basis test is “highly deferential to the legislature.” In re Det. of Thorell, 149 Wn.2d 724, 749 , 72 P.3d 708 (2003).

2006Such over- or underinclusiveness does not defeat finding a rational basis. ¶70 The rational basis standard of review is “highly deferential to the legislature.” In re Det. of Thorell, 149 Wn.2d 724, 749 , 72 P.3d 708 (2003).

2010Following Manussier and Thorne , we apply rational basis scrutiny to Langstead’s challenge. ¶10 “Under the rational basis test, a statute is constitutional if (1) the legislation applies alike to all persons within a designated class; (2) reasonable grounds exist for distinguishing between those who fall within the class and those who do not; and (3) the classification has a rational relationship to the purpose of the legislation.” State v. Smith, 117 Wn.2d 263, 279 , 814 P.2d 652 (1991).

2010Following Manussier and Thorne , we apply rational basis scrutiny to Langstead’s challenge. ¶10 “Under the rational basis test, a statute is constitutional if (1) the legislation applies alike to all persons within a designated class; (2) reasonable grounds exist for distinguishing between those who fall within the class and those who do not; and (3) the classification has a rational relationship to the purpose of the legislation.” State v. Smith, 117 Wn.2d 263, 279 , 814 P.2d 652 (1991).

2025Therefore, the classification is subject to minimal judicial scrutiny under the rational basis test. 18 Osman, 157 Wn.2d at 484 ; Shawn P., 122 Wn.2d at 560 ; see also In re Pers.

2025“We apply strict scrutiny if the individual is a member of a suspect class or the state action threatens a fundamental right, intermediate scrutiny if the individual is member of a ‘semisuspect’ class or the state action threatens ‘important’ rights, and the rational basis test if neither strict scrutiny nor intermediate scrutiny is applied.” Id. (quoting State v. Osman, 157 Wn.2d 474, 484 , 139 P.3d 334 (2006)). 2.

2001More succinctly, "[u]nder the rational basis test the challenged law must be rationally related to a legitimate state interest." Seeley v. State, 132 Wash.2d 776, 795 , 940 P.2d 604 (1997).

2001More succinctly, “[u]nder the rational basis test the challenged law must be rationally related to a legitimate state interest.” Seeley v. State, 132 Wn.2d 776, 795 , 940 P.2d 604 (1997).

2016The rational basis test is “highly deferential to the legislature.” In re Det. of Thorell, 149 Wn.2d 724, 749 , 72 P.3d 708 (2003).

2006Such over- or underinclusiveness does not defeat finding a rational basis. ¶70 The rational basis standard of review is “highly deferential to the legislature.” In re Det. of Thorell, 149 Wn.2d 724, 749 , 72 P.3d 708 (2003).

2006In fact, "the rational basis standard may be satisfied where the `legislative choice ... [is] based on rational speculation unsupported by evidence or empirical data.'" DeYoung, 136 Wash.2d at 148 , 960 P.2d 919 (alteration in original) (quoting Fed.

2006Finding this link, or rational basis, ensures that "classifications are not drawn for the purpose of disadvantaging the group burdened by the law." Id. at 633 , 116 S.Ct. 1620 . [15] ś 253 Despite the deference afforded to the legislature, the rational basis standard is not without teethâ "the court's role is to assure that even under this deferential standard of review the challenged legislation is constitutional." [16] DeYoung, 136 Wash.2d at 144 , 960 P.2d 919 .

2008Third, under the rational relationship test, ‘a law is subjected to minimal scrutiny and will be upheld “ ‘unless it rests on grounds wholly irrelevant to the achievement of a legitimate state objective.’ ” ’ Schaaf , at 17 (quoting Phelan , at 512 (quoting Nielsen v. Washington State Bar Ass’n, 90 Wn.2d 818, 820 , 585 P.2d 1191 (1978))).” State v. Heiskell, 129 Wn.2d 113, 123-24 , 916 P.2d 366 (1996) (alterations in original) (quoting Westerman v. Cary, 125 Wn.2d 277, 294-95 , 885 P.2d 827 , 892 P.2d 1067 (1994)). ¶83 Prisoners are neither a suspect nor a semisuspect classification, so the ra

2008Third, under the rational relationship test, `a law is subjected to minimal scrutiny and will be upheld "`unless it rests on grounds wholly irrelevant to the achievement of a legitimate state objective.'"' Schaaf, at 17, 743 P.2d 240 (quoting Phelan, at 512, 671 P.2d 1212 (quoting Nielsen v. Washington State Bar Ass'n, 90 Wash.2d 818, 820 , 585 P.2d 1191 (1978)))." State v. Heiskell, 129 Wash.2d 113, 123-24 , 916 P.2d 366 (1996) (alterations in original) (quoting Westerman v. Cary, 125 Wash.2d 277, 294-95 , 892 P.2d 1067 (1994)). ¶ 81 Prisoners are neither a suspect nor a semisuspect classific

2008Third, under the rational relationship test, ‘a law is subjected to minimal scrutiny and will be upheld “ ‘unless it rests on grounds wholly irrelevant to the achievement of a legitimate state objective.’ ” ’ Schaaf , at 17 (quoting Phelan , at 512 (quoting Nielsen v. Washington State Bar Ass’n, 90 Wn.2d 818, 820 , 585 P.2d 1191 (1978))).” State v. Heiskell, 129 Wn.2d 113, 123-24 , 916 P.2d 366 (1996) (alterations in original) (quoting Westerman v. Cary, 125 Wn.2d 277, 294-95 , 885 P.2d 827 , 892 P.2d 1067 (1994)). ¶83 Prisoners are neither a suspect nor a semisuspect classification, so the ra

2008Third, under the rational relationship test, `a law is subjected to minimal scrutiny and will be upheld "`unless it rests on grounds wholly irrelevant to the achievement of a legitimate state objective.'"' Schaaf, at 17, 743 P.2d 240 (quoting Phelan, at 512, 671 P.2d 1212 (quoting Nielsen v. Washington State Bar Ass'n, 90 Wash.2d 818, 820 , 585 P.2d 1191 (1978)))." State v. Heiskell, 129 Wash.2d 113, 123-24 , 916 P.2d 366 (1996) (alterations in original) (quoting Westerman v. Cary, 125 Wash.2d 277, 294-95 , 892 P.2d 1067 (1994)). ¶ 81 Prisoners are neither a suspect nor a semisuspect classific

1993Co. v. Marquardt, 115 Wn.2d 416, 431 , 799 P.2d 235 (1990). *651 [21] Under the rational basis test, "a statutory classification violates the equal protection clause only if it fails to rationally further a legitimate state interest".

1993Co. v. Marquardt, 115 Wn.2d 416, 431 , 799 P.2d 235 (1990). *651 [21] Under the rational basis test, "a statutory classification violates the equal protection clause only if it fails to rationally further a legitimate state interest".

2022“The rational basis test requires only that the means employed by the statute be rationally related to legitimate state goals, and not that the means be the best way of achieving that goal.” Id.

2001More succinctly, “[u]nder the rational basis test the challenged law must be rationally related to a legitimate state interest.” Seeley v. State, 132 Wn.2d 776, 795 , 940 P.2d 604 (1997).

1998Indeed, the rational basis standard may be satisfied where the “legislative choice . . . [is] based on rational speculation unsupported by evidence or empirical data.” F.C.C. v. Beach Communications, Inc., 508 U.S. 307, 315 , 113 S. Ct. 2096 , 124 L.

1998Indeed, the rational basis standard may be satisfied where the “legislative choice . . . [is] based on rational speculation unsupported by evidence or empirical data.” F.C.C. v. Beach Communications, Inc., 508 U.S. 307, 315 , 113 S. Ct. 2096 , 124 L.

2011Ward, 123 Wn.2d at 516 .

1994"A statute that does not affect fundamental rights or create a suspect classification is subject to minimal judicial scrutiny under the rational basis test.” State v. Ward, 123 Wn.2d 488, 516 , 869 P.2d 1062 (1994).

2008I find this distinction perplexing. ś 129 "`Under the rational basis test the court must determine: . . . whether there are reasonable grounds to distinguish between those within and those without the class. . . .'" Griffin v. Eller, 130 Wash.2d 58, 65 , 922 P.2d 788 (1996) (quoting Convention Ctr.

2008I find this distinction perplexing. ¶128 “ ‘Under the rational basis test the court must determine: . . . whether there are reasonable grounds to distinguish between those within and those without the class ....’” Griffin v. Eller, 130 Wn.2d 58, 65 , 922 P.2d 788 (1996) (quoting Convention Ctr.

2003Willoughby, 147 Wn.2d at 739 ; Harris, 120 Wn.2d at 477 .

2003Harris, 120 Wn.2d at 477 .

2025“We apply strict scrutiny if the individual is a member of a suspect class or the state action threatens a fundamental right, intermediate scrutiny if the individual is member of a ‘semisuspect’ class or the state action threatens ‘important’ rights, and the rational basis test if neither strict scrutiny nor intermediate scrutiny is applied.” Id. (quoting State v. Osman, 157 Wn.2d 474, 484 , 139 P.3d 334 (2006)). 2.

2020App. 380 , 367 P.3d 612 (2016); State v. Blazina, 182 Wn.2d 827 , 344 P.3d 680 (2015). 14 State v. Osman, 157 Wn.2d 474 , 483 n. 11, 139 P.3d 334 (2006). 15 State v. Shawn P., 122 Wn.2d 553, 559-60 , 859 P.2d 1220 (1993). 16 Osman, 157 Wn.2d at 484 . 17 State v. Hirschfelder, 170 Wn.2d 536, 550 , 242 P.3d 876 (2010). 7 No. 80294-1-I/8 review. 18 To conduct rational basis review, we apply the following standards: Under the rational basis test, state action does not violate the equal protection clause if there is a rational relationship between the classification and a legitimate state interest.

2010Manussier, 129 Wash.2d at 673-74 , 921 P.2d 473 ; Thorne, 129 Wash.2d at 771 , 921 P.2d 514 ("Recidivist criminals are not a semisuspect class.").

2010"The burden is on the party challenging the classification to show that it is purely arbitrary." Thorne, 129 Wash.2d at 771 , 921 P.2d 514 . ¶ 11 Langstead's argument is under the second prong of the test.

2006Bd. of Trustees of the University of Alabama v. Garrett, 531 U.S. 356, 367 , 121 S.Ct. 955 , 148 L.Ed.2d 866 (2001); Heller, 509 U.S. at 320 , 113 S.Ct. 2637 ; Seeley v. State, 132 Wash.2d 776, 795 , 940 P.2d 604 (1997).

2006Bd. of Trustees of the University of Alabama v. Garrett, 531 U.S. 356, 367 , 121 S.Ct. 955 , 148 L.Ed.2d 866 (2001); Heller, 509 U.S. at 320 , 113 S.Ct. 2637 ; Seeley v. State, 132 Wash.2d 776, 795 , 940 P.2d 604 (1997).