rational basis test in Ohio

2022“Under the rational basis standard, we are to grant substantial deference to the predictive judgment of the General Assembly.” State v. Williams, 88 Ohio St.3d 513 , 531, 728 N.E.2d 342 (2000). {¶ 25} The government has a legitimate interest in deterring drunk driving.

2022“Under the rational basis standard, we are to grant substantial deference to the predictive judgment of the General Assembly.” State v. Williams, 88 Ohio St.3d 513, 531 , 728 N.E.2d 342 (2000). {¶ 25} The government has a legitimate interest in deterring drunk driving.

2002See, e.g., McGowan v. Maryland (1961), 366 U.S. 420 , 81 S.Ct. 1101 , 6 L.Ed.2d 393 [ 17 O.O.2d 151 ], for the traditional scrutiny test; see, e.g., Shapiro v. Thompson (1969), 394 U.S. 618 , 89 S.Ct. 1322 , 22 L.Ed.2d 600 ; Harper v. Virginia Bd. of Elections (1966), 383 U.S. 663 , 86 S.Ct. 1079 , 16 L.Ed.2d 169 ; Griswold v. Connecticut (1965), 381 U.S. 479 , 85 S.Ct. 1678 , 14 L.Ed.2d 510 for a discussion of `fundamental interest'; and see, e.g., Graham v. Richardson (1971), 403 U.S. 365 , 91 S.Ct. 1848 , 29 L.Ed.2d 534 ; Loving v. Virginia (1967), 388 U.S. 1 , 87 S.Ct. 1817 , 18 L.Ed.2d 10

2002See, e.g., McGowan v. Maryland (1961), 366 U.S. 420 , 81 S.Ct. 1101 , 6 L.Ed.2d 393 [ 17 O.O.2d 151 ], for the traditional scrutiny test; see, e.g., Shapiro v. Thompson (1969), 394 U.S. 618 , 89 S.Ct. 1322 , 22 L.Ed.2d 600 ; Harper v. Virginia Bd. of Elections (1966), 383 U.S. 663 , 86 S.Ct. 1079 , 16 L.Ed.2d 169 ; Griswold v. Connecticut (1965), 381 U.S. 479 , 85 S.Ct. 1678 , 14 L.Ed.2d 510 for a discussion of `fundamental interest'; and see, e.g., Graham v. Richardson (1971), 403 U.S. 365 , 91 S.Ct. 1848 , 29 L.Ed.2d 534 ; Loving v. Virginia (1967), 388 U.S. 1 , 87 S.Ct. 1817 , 18 L.Ed.2d 10

2025More precisely, the Supreme Court has held that under the less stringent rational basis standard, the challenged law must “ ‘bear[] a real and substantial relation to the public health, safety, morals or general welfare of the public’ ” and not be “ ‘unreasonable or arbitrary.’ ” Arbino, 2007- Ohio-6948 at ¶ 49, quoting Mominee v. Scherbarth, 28 Ohio St.3d 270, 274 (1986), quoting Benjamin v. Columbus, 167 Ohio St. 103 (1957), paragraph five of the syllabus.

2022In addressing that question, this court applied the rational-basis test under which a statute is deemed valid “ ‘ “[1] if it bears a real and substantial relation to the public health, safety, morals or general welfare of the public and [2] if it is not unreasonable or arbitrary.” ’ ” (Brackets added in Mominee.) Id. at ¶ 49, quoting Mominee v. Scherbarth, 28 Ohio St.3d 270 , 274, 503 N.E.2d 717 (1986), quoting Benjamin v. Columbus, 167 Ohio St. 103 , 146 N.E.2d 854 (1957), paragraph five 12 January Term, 2022 of the syllabus.

2025Relying on Schwan v. Riverside Methodist Hosp., 6 Ohio St.3d 300 (1983), the Morris court explained that, where there is an equal protection challenge reviewed under the rational-basis test, “the statute must be upheld if there exists any conceivable set of facts under which the classification rationally furthered a legitimate legislative objective.” Morris at 689, 692 .

2022Ruther, 134 Ohio St.3d 408 , 2012-Ohio-5686 , 983 N.E.2d 291, ¶ 19-21 (concluding that the General Assembly had a rational basis to enact its policy decision limiting the time within which a medical malpractice action can be pursued); see also Morris v. Savoy, 61 Ohio St.3d 684, 689 , 576 N.E.2d 765 (1991) (medical malpractice claims do not involve a fundamental right or suspect class so that any equal protection analysis is limited to the rational-basis test).

2021Id., citing Clements at 963 ; see also Cleburne v. Cleburne Living Ctr., 473 U.S. 432, 440 , 105 S.Ct. 3249 , 87 L.Ed.2d 313 (1985). {¶105} The former version of R.C. 2901.09(B) provides that “[f]or purposes of any section of the Revised Code that sets forth a criminal offense, a person who lawfully is in that person’s residence has no duty to retreat before using force in self-defense, defense of another, or defense of that person’s residence, and a person who lawfully is an occupant of that person’s vehicle or who lawfully is an occupant in a vehicle owned by an immediate family member of th

2021Id., citing Clements at 963 ; see also Cleburne v. Cleburne Living Ctr., 473 U.S. 432, 440 , 105 S.Ct. 3249 , 87 L.Ed.2d 313 (1985). {¶105} The former version of R.C. 2901.09(B) provides that “[f]or purposes of any section of the Revised Code that sets forth a criminal offense, a person who lawfully is in that person’s residence has no duty to retreat before using force in self-defense, defense of another, or defense of that person’s residence, and a person who lawfully is an occupant of that person’s vehicle or who lawfully is an occupant in a vehicle owned by an immediate family member of th

2015In other words, “[u]nder the rational-basis test, a statute survives if it is reasonably related to a legitimate government interest.” (Citation omitted.) State v. Lowe, 112 Ohio St.3d 507 , 2007-Ohio-606 , 861 N.E.2d 512, ¶ 18 . {¶ 10} Similarly, under a traditional equal protection analysis, “ ‘[a] statutory classification which involves neither a suspect class nor a fundamental right does not violate the Equal Protection Clause of the Ohio or United States Constitutions if it bears a rational relationship to a legitimate governmental interest.’ ” McCrone v. Bank One Corp., 107 Ohio St.3d 27

2015In other words, “[u]nder the rational-basis test, a statute survives if it is reasonably related to a legitimate government interest.” (Citation omitted.) State v. Lowe, 112 Ohio St.3d 507 , 2007-Ohio-606 , 861 N.E.2d 512, ¶ 18 . {¶ 10} Similarly, under a traditional equal protection analysis, “ ‘[a] statutory classification which involves neither a suspect class nor a fundamental right does not violate the Equal Protection Clause of the Ohio or United States Constitutions if it bears a rational relationship to a legitimate governmental interest.’ ” McCrone v. Bank One Corp., 107 Ohio St.3d 27

2024Thus, provided that the statute is rationally related to a legitimate government interest, it will be upheld.” (Citations omitted.) Id., quoting id. at ¶ 9. {¶17} A review of the record indicates that after construing all material factual allegations in the complaint, and all reasonable inferences, the trial court abused its discretion when it determined that the appellants could prove no set of facts related to its failure to be reimbursed funds despite no longer being employed by the county. {¶18} “According to the rational-basis test, lawmakers may create distinctions that bear a rational r

2022See McCrone v. Bank One Corp., 107 Ohio St.3d 272 , 2005-Ohio- 6505, 839 N.E.2d 1, ¶ 8 ; Estelle v. Dorrough, 420 U.S. 534, 538 , 95 S.Ct. 1173 , 43 L.Ed.2d 377 (1975) (“this Court in dealing with equal protection challenges to state regulation of the right of appeal in criminal cases ha[s] applied the traditional rational-basis test”).

2002See, e.g., McGowan v. Maryland (1961), 366 U.S. 420 , 81 S.Ct. 1101 , 6 L.Ed.2d 393 [ 17 O.O.2d 151 ], for the traditional scrutiny test; see, e.g., Shapiro v. Thompson (1969), 394 U.S. 618 , 89 S.Ct. 1322 , 22 L.Ed.2d 600 ; Harper v. Virginia Bd. of Elections (1966), 383 U.S. 663 , 86 S.Ct. 1079 , 16 L.Ed.2d 169 ; Griswold v. Connecticut (1965), 381 U.S. 479 , 85 S.Ct. 1678 , 14 L.Ed.2d 510 for a discussion of `fundamental interest'; and see, e.g., Graham v. Richardson (1971), 403 U.S. 365 , 91 S.Ct. 1848 , 29 L.Ed.2d 534 ; Loving v. Virginia (1967), 388 U.S. 1 , 87 S.Ct. 1817 , 18 L.Ed.2d 10

2002See, e.g., McGowan v. Maryland (1961), 366 U.S. 420 , 81 S.Ct. 1101 , 6 L.Ed.2d 393 [ 17 O.O.2d 151 ], for the traditional scrutiny test; see, e.g., Shapiro v. Thompson (1969), 394 U.S. 618 , 89 S.Ct. 1322 , 22 L.Ed.2d 600 ; Harper v. Virginia Bd. of Elections (1966), 383 U.S. 663 , 86 S.Ct. 1079 , 16 L.Ed.2d 169 ; Griswold v. Connecticut (1965), 381 U.S. 479 , 85 S.Ct. 1678 , 14 L.Ed.2d 510 for a discussion of `fundamental interest'; and see, e.g., Graham v. Richardson (1971), 403 U.S. 365 , 91 S.Ct. 1848 , 29 L.Ed.2d 534 ; Loving v. Virginia (1967), 388 U.S. 1 , 87 S.Ct. 1817 , 18 L.Ed.2d 10

1988This rational basis standard involves a high degree of judicial deference to legislative bodies. * * *” In Allied Stores of Ohio, Inc. v. Berners (1959), 358 U.S. 522, 526-528 , the United States Supreme Court stated: “* * * The States have a very wide discretion in the laying of their taxes.

1987The Ohio Supreme Court, in Bd. of Edn. v. Walter (1979), 58 Ohio St. 2d 368, 376 , 12 O.O. 3d 327, 332, 390 N.E. 2d 813, 819 , citing Allied Stores of Ohio v. Bowers (1959), 358 U.S. 522, 530 , 9 O.O. 2d 321, 326, stated that under a rational basis analysis, any classification based “* * * ‘upon a state of facts that reasonably can be conceived to constitute a distinction, or differences in state policy * * *' will be upheld * * Only if the classifications are wholly unrelated to the accomplishment of a legitimate state objective will there be an equal protection violation.

2017Cleveland v. McCardle , 139 Ohio St.3d 414 , 2014-Ohio-2140 , 12 N.E.3d 1169 , ¶ 11 ; Massachusetts Bd. of Retirement v. Murgia , 427 U.S. 307 , 312, 96 S.Ct. 2562 , 49 L.Ed.2d 520 (1976). {¶ 72} R.C. 2744.05(C)(1) involves neither a suspect class nor a fundamental right, so we again apply the rational basis test to determine if the classification has some reasonable basis.

2017Cleveland v. McCardle , 139 Ohio St.3d 414 , 2014-Ohio-2140 , 12 N.E.3d 1169 , ¶ 11 ; Massachusetts Bd. of Retirement v. Murgia , 427 U.S. 307 , 312, 96 S.Ct. 2562 , 49 L.Ed.2d 520 (1976). {¶ 72} R.C. 2744.05(C)(1) involves neither a suspect class nor a fundamental right, so we again apply the rational basis test to determine if the classification has some reasonable basis.

1993“Where, as here, the legislative distinctions do not affect a ‘suspect class’ or infringe upon a fundamental right, and impinge on mere economic interests, courts apply a rational basis test[.]” Sedar, supra. Under the rational basis test, a statute will be upheld if the classification is based upon “facts that reasonably can be conceived to constitute a distinction, or differences in state policy * * *.” Bd. of Edn. v. Walter, supra, 58 Ohio St.2d at 376 , 12 O.O.3d at 332 , 390 N.E.2d at 819 , certiorari denied (1980), 444 U.S. 1015 , 100 S.Ct. 665 , 62 L.Ed.2d 644 .

1993“Where, as here, the legislative distinctions do not affect a ‘suspect class’ or infringe upon a fundamental right, and impinge on mere economic interests, courts apply a rational basis test[.]” Sedar, supra. Under the rational basis test, a statute will be upheld if the classification is based upon “facts that reasonably can be conceived to constitute a distinction, or differences in state policy * * *.” Bd. of Edn. v. Walter, supra, 58 Ohio St.2d at 376 , 12 O.O.3d at 332 , 390 N.E.2d at 819 , certiorari denied (1980), 444 U.S. 1015 , 100 S.Ct. 665 , 62 L.Ed.2d 644 .

2024State v. Mole, 149 Ohio St.3d 215 , 2016-Ohio- 5124, ¶ 28, citing Holeton v. Crouse Cartage Co., 92 Ohio St.3d 115, 131 (2001).

2007Thus, to satisfy the rational-basis test, R.C. 4123.931 must satisfy the constitutional requirement that “subrogable or recoupable items be matched to those losses or types of damages that the claimant actually recovered from the tortfeasor.” Id. *714 {¶ 26} In the case sub judice, regarding the issues of double recovery and matching, Smith argues that the formula assumes that the benefits paid by the BWC were duplicated in the recovery and disregards the matching requirement.

2020Adamsky v. Buckeye Local School Dist., 73 Ohio St.3d 360, 362 (1995). {¶21} Appellant acknowledges that the rational-basis standard of review applies, and that the state of Ohio has a legitimate interest in highway safety and keeping impaired drivers off the road.

2004Under the rational basis test, legislation will be upheld against an equal protection challenge if it "bears a rational relationship to a legitimate governmental interest." Adamsky v. Buckeye Local School Dist., 73 Ohio St.3d 360 , 362 , 1995-Ohio-298 .

2015Heller v. Miller, 61 Ohio St.2d 6, 11 , 399 N.E.2d 66 (1980) (“ ‘Under the equal protection clause, in the absence of state action impinging on a fundamental interest or involving a suspect class, a rational basis analysis is normally used’ ”). {¶ 51} As the United States Supreme Court has articulated, “a classification neither involving fundamental rights nor proceeding along suspect lines is accorded a strong presumption of validity.” Heller v. Doe, 509 U.S. 312, 319 , 113 S.Ct. 2637 , 125 L.Ed.2d 257 (1993).

2015Heller v. Miller, 61 Ohio St.2d 6, 11 , 399 N.E.2d 66 (1980) (“ ‘Under the equal protection clause, in the absence of state action impinging on a fundamental interest or involving a suspect class, a rational basis analysis is normally used’ ”). {¶ 51} As the United States Supreme Court has articulated, “a classification neither involving fundamental rights nor proceeding along suspect lines is accorded a strong presumption of validity.” Heller v. Doe, 509 U.S. 312, 319 , 113 S.Ct. 2637 , 125 L.Ed.2d 257 (1993).

2023“This rational basis analysis is discarded for a higher level of scrutiny only where the challenged statute involves a suspect class or a fundamental constitutional right.” Id. {¶ 101} Kocevar has not supplied authority indicating juveniles are a suspect class.

2000See Clements, 457 U.S. at 963 , 102 S.Ct. at 2843 , 73 L.Ed.2d at 515 . {¶ 70} Under the rational basis standard, we are to grant substantial deference to the predictive judgment of the General Assembly.

2025Under the rational-basis test, R.C. 2323.43 must be upheld if it “[1] bears a real and substantial relation to the public health, safety, morals or general welfare of the public and [2] if it is not unreasonable or arbitrary.” (Brackets in original.) (Internal quotation marks deleted and citation omitted.) Arbino, 2007-Ohio-6948, at ¶ 49 .

2024Id. {¶ 21} There is no doubt that the rational-basis test applies in this case.

2015Heller v. Miller, 61 Ohio St.2d 6, 11 , 399 N.E.2d 66 (1980) (“ ‘Under the equal protection clause, in the absence of state action impinging on a fundamental interest or involving a suspect class, a rational basis analysis is normally used’ ”). {¶ 51} As the United States Supreme Court has articulated, “a classification neither involving fundamental rights nor proceeding along suspect lines is accorded a strong presumption of validity.” Heller v. Doe, 509 U.S. 312, 319 , 113 S.Ct. 2637 , 125 L.Ed.2d 257 (1993).

2015Heller v. Miller, 61 Ohio St.2d 6, 11 , 399 N.E.2d 66 (1980) (“ ‘Under the equal protection clause, in the absence of state action impinging on a fundamental interest or involving a suspect class, a rational basis analysis is normally used’ ”). {¶ 51} As the United States Supreme Court has articulated, “a classification neither involving fundamental rights nor proceeding along suspect lines is accorded a strong presumption of validity.” Heller v. Doe, 509 U.S. 312, 319 , 113 S.Ct. 2637 , 125 L.Ed.2d 257 (1993).

2005Comm. (1983), 2 Ohio St.3d 173, 179 , 2 OBR 715, 443 N.E.2d 962 (Krupansky, J., dissenting), quoting Dandridge v. Williams (1970), 397 U.S. 471, 485 , 90 S.Ct. 1153 , 25 L.Ed.2d 491 . {¶ 9} The rational-basis test involves a two-step analysis.

2005Comm. (1983), 2 Ohio St.3d 173, 179 , 2 OBR 715, 443 N.E.2d 962 (Krupansky, J., dissenting), quoting Dandridge v. Williams (1970), 397 U.S. 471, 485 , 90 S.Ct. 1153 , 25 L.Ed.2d 491 . {¶ 9} The rational-basis test involves a two-step analysis.

2022Ruther, 134 Ohio St.3d 408 , 2012-Ohio-5686 , 983 N.E.2d 291, ¶ 19-21 (concluding that the General Assembly had a rational basis to enact its policy decision limiting the time within which a medical malpractice action can be pursued); see also Morris v. Savoy, 61 Ohio St.3d 684, 689 , 576 N.E.2d 765 (1991) (medical malpractice claims do not involve a fundamental right or suspect class so that any equal protection analysis is limited to the rational-basis test).

2017In reviewing an ordinance “on due-process grounds, [a court should] apply a rational-basis test unless the statute restricts the exercise of fundamental rights.” Arbino v. Johnson & Johnson, 116 Ohio St.3d 468 , 2007-Ohio-6948 , 880 N.E.2d 420, ¶ 49 , citing -8- Sorrell v. Thevenir, 69 Ohio St.3d 415, 423 , 633 N.E.2d 504 (1994), and Morris v. Savoy, 61 Ohio St.3d 684, 688-689 , 576 N.E.2d 765 (1991).

2022See also F.C.C. v. Beach Communications, Inc., 508 U.S. 307, 313 , 113 S.Ct. 2096 , 124 L.Ed.2d 211 (1993) (when the rational basis test applies, there is a strong presumption of constitutionality and the challenger has the burden of disputing every reasonably conceivable basis). {¶34} Appellant concedes the municipal court’s mask order is neutral on its face, and there is no allegation of a religion-related motivation behind the order.

2022See also F.C.C. v. Beach Communications, Inc., 508 U.S. 307, 313 , 113 S.Ct. 2096 , 124 L.Ed.2d 211 (1993) (when the rational basis test applies, there is a strong presumption of constitutionality and the challenger has the burden of disputing every reasonably conceivable basis). {¶34} Appellant concedes the municipal court’s mask order is neutral on its face, and there is no allegation of a religion-related motivation behind the order.

2007See, e.g., DeSenco , 84 Ohio St.3d at 544 (disposing of equal protection claim on fundamental right to vote in a motion to dismiss); Fahnbulleh v. Strahan (1995), 73 Ohio St.3d 666 , 668 (upholding dismissal finding statute reasonably calculated to advance legitimate government interests and concluding there was no equal protection violation). 1 Thus, we can proceed to evaluate whether the legislature has a rational basis for treating school districts differently where they are financially distressed. {¶ 46} The rational basis test provides that a statute shall be held constitutional "if it be

2006Also viewed under the rational-basis test, a municipal enactment comports with due process "`if it bears a real and substantial relation to the public health, safety, morals or general welfare of the public and if it is not unreasonable or arbitrary.'" Id., quoting Benjamin v. Columbus (1957), 167 Ohio St. 103 , 110 . {¶ 54} Legislation enjoys a strong presumption of constitutionality, which remains unless the challenging party establishes beyond a reasonable doubt that the legislation is unconstitutional.

2022Skilled Gaming, L.L.C. v. Cordray, 127 Ohio St.3d 104 , 2010-Ohio-4908 , 936 N.E.2d 944 , ¶ 32, and it requires a court to uphold a legislative classification if the classification is rationally related to a legitimate governmental purpose, Roseman v. Firemen & Policemen’s Death Benefit Fund, 66 Ohio St.3d 443, 447 , 613 N.E.2d 574 (1993); Noling at ¶ 14 , citing Clark v. Jeter, 486 U.S. 456, 461 , 108 S.Ct. 1910 , 100 L.Ed.2d 465 (1988).

1998"Under a rational basis analysis, a statutory classification does not violate equal protection if it bears a rational relationship to a legitimate governmental interest." Van Der Veer at 65 , citing Roseman v. Firemen Policemen's Death Benefit Fund (1993), 66 Ohio St.3d 443 .

2015Communications Comm., 520 U.S. 180, 195 , 117 S.Ct. 1174 , 137 L.Ed.2d 369 (1997) (“Under the rational basis standard, we are to grant substantial deference to the predictive judgment of the General Assembly”).

2015Communications Comm., 520 U.S. 180, 195 , 117 S.Ct. 1174 , 137 L.Ed.2d 369 (1997) (“Under the rational basis standard, we are to grant substantial deference to the predictive judgment of the General Assembly”).

1990Where, as here, the legislative distinctions do not affect a “suspect class” or infringe upon a fundamental right, and impinge on mere economic interests, courts apply a rational basis test: “ ‘[U]nequal treatment of classes of persons by a state is valid only if the state can show that a rational basis exists for the inequality * * V ” Id. at 492 , 21 O.O. 3d at 307, 424 N.E. 2d at 592 , quoting Bd. of Edn. v. Walter (1979), 58 Ohio St. 2d 368, 373 , 12 O.O. 3d 327, 330, 390 N.E. 2d 813, 818 .

1990Where, as here, the legislative distinctions do not affect a “suspect class” or infringe upon a fundamental right, and impinge on mere economic interests, courts apply a rational basis test: “ ‘[U]nequal treatment of classes of persons by a state is valid only if the state can show that a rational basis exists for the inequality * * V ” Id. at 492 , 21 O.O. 3d at 307, 424 N.E. 2d at 592 , quoting Bd. of Edn. v. Walter (1979), 58 Ohio St. 2d 368, 373 , 12 O.O. 3d 327, 330, 390 N.E. 2d 813, 818 .