rational basis test in Minnesota

2011In Russell , we stated that we have “not been consistent in explaining whether the rational basis standard under Minnesota law, although articulated differently, is identical to the federal standard or represents a less deferential standard under the Minnesota Constitution.” 477 N.W.2d at 889 .

2004Likewise, we apply a rational-basis standard under the Minnesota Constitution and require “a reasonable connection between the actual, and not just the theoretical, effect of the challenged classification and the statutory goals.” State v. Russell, 477 N.W.2d 886, 888-89 (Minn.1991) (citations omitted).

2005We articulated the three parts to this rational basis test in Miller Brewing Co. v. State: (1) The distinctions which separate those included within the classification from those excluded must not be manifestly arbitrary or fanciful but must be genuine and substantial, thereby providing a natural and reasonable basis to justify legislation adapted to peculiar conditions and needs; (2) the classification must be genuine or relevant to the purpose of the law; that is, there must be an evident connection between the distinctive needs peculiar to the class and the prescribed remedy; (3) the purpos

1995The second prong of the rational basis test requires that the statutory classification serve some “distinctive need[ ] peculiar to the class.” Miller, 284 N.W.2d at 356 .

2011AFSCME, 338 N.W.2d at 573-75 .

1986In reviewing challenges to the constitutionality of legislative classifications, this court has stated: “[I]t must be recognized that statutes carry a presumption of constitutionality, and that it is not the role of the judiciary, in applying the rational basis standard, to question either the factual accuracy or political wisdom of the reasoning and judgment underlying the legislative enactment.” AFSCME Councils 6, 14, 65 & 96 v. Sundquist, 338 N.W.2d 560, 570 (Minn.1983).

2003See Scott, 615 N.W.2d at 74 (stating that under the rational-basis standard of review, a statute is presumed valid and will be upheld if the classification drawn by it is rationally related to a legitimate state interest).

2001Unless an equal protection challenge “involves a suspect classification or a fundamental right, we review the challenge under a rational basis standard under both the state and federal constitutions.” Id.

2024But when no fundamental right is at stake, appellate courts apply the rational-basis test, and a challenged statute will be deemed constitutional if it “provide[s] a reasonable means to a permissible objective.” Id.

2024Under the rational-basis test, the statute must “serve to promote 5 a public purpose”; the statute must “not be an unreasonable, arbitrary or capricious interference with a private interest”; and “the means chosen [must] bear a rational relation to the public purpose sought to be served.” Id. at 718 (quotations omitted).

2018Under the federal constitution, the rational basis test is satisfied if "the classification drawn by the statute is rationally related to a legitimate state interest." City of Cleburne v. Cleburne Living Ctr. , 473 U.S. 432 , 440, 105 S.Ct. 3249 , 87 L.Ed.2d 313 (1985).

2018Under the federal constitution, the rational basis test is satisfied if "the classification drawn by the statute is rationally related to a legitimate state interest." City of Cleburne v. Cleburne Living Ctr. , 473 U.S. 432 , 440, 105 S.Ct. 3249 , 87 L.Ed.2d 313 (1985).

2019Although the rational-basis test applied under the Minnesota Constitution sometimes differs from that applied under the United States Constitution, equal-protection analysis under both constitutions "begin[s] with the mandate that all similarly situated individuals shall be treated alike." Kolton v. County of Anoka , 645 N.W.2d 403 , 411 (Minn. 2002) ; see also City of Golden Valley v. Wiebesick , 899 N.W.2d 152 , 157 (Minn. 2017) ("We favor uniformity with the federal constitution because of the primacy of the federal constitution in matters affecting individual liberties and to encourage con

2003Under both the United States and Minnesota Constitutions, “[i]f a constitutional challenge involves neither a suspect classification nor a fundamental right, we review the challenge under a rational basis standard.” Kolton v. County of Anoka, 645 N.W.2d 403, 411 (Minn.2002) (citation omitted).

2002State v. Russell, 477 N.W.2d 886, 888 (Minn.1991) (quoting Wegan v. Village of Lexington, 309 N.W.2d 273, 280 (Minn. *412 1981)). 5 Resolution of Kolton’s constitutional claims does not depend on which formulation of the rational basis test applies.

1991Wegan v. Village of Lexington, 309 N.W.2d 273, 280 (Minn.1981) (quoting Guilliams v. Commissioner of Revenue, 299 N.W.2d 138, 142 (1980)). *889 This court has not been consistent in explaining whether the rational basis standard under Minnesota law, although articulated differently, is identical to the federal standard or represents a less deferential standard under the Minnesota Constitution. [3] What has been consistent, however, is that in the cases where we have applied what may be characterized as the Minnesota rational basis analysis, we have been unwilling to hypothesize a rational basi

2006State v. Russell, 477 N.W.2d 886, 888 (Minn.1991) (quoting Wegan v. Village of Lexington, 309 N.W.2d 273, 280 (Minn.1981) (quoting Guilliams v. Comm’r of Revenue, 299 N.W.2d 138, 142 (Minn.1980))).

1991Wegan v. Village of Lexington, 309 N.W.2d 273, 280 (Minn.1981) (quoting Guilliams v. Commissioner of Revenue, 299 N.W.2d 138, 142 (1980)). *889 This court has not been consistent in explaining whether the rational basis standard under Minnesota law, although articulated differently, is identical to the federal standard or represents a less deferential standard under the Minnesota Constitution. [3] What has been consistent, however, is that in the cases where we have applied what may be characterized as the Minnesota rational basis analysis, we have been unwilling to hypothesize a rational basi

2019Distillers , 229 N.W.2d at 156 (denying an equal-protection challenge to a statute requiring all licensed distillers of liquor to offer their products for sale to all Minnesota wholesalers on an equal basis but not extending that requirement to include wines and malt beverages). "[O]nly invidious discrimination is deemed constitutionally offensive." Garcia , 683 N.W.2d at 298 (quotation omitted). *427 We review an equal-protection challenge under a rational-basis standard unless the challenge involves a suspect classification or a fundamental right.

2016We review an equal protection challenge to a statute “under a rational basis standard unless the challenge involves a suspect classification or a fundamental right.” State v. Garcia, 683 N.W.2d 294, 298 (Minn. 2004).

2015See Reno v. Flores, 507 U.S. 292, 305 , 113 S. Ct. 1439 , 1448–49 (1993); In re Individual 35W Bridge Litigation, 806 N.W.2d 820, 830 (Minn. 2011).

2015See Reno v. Flores, 507 U.S. 292, 305 , 113 S.Ct. 1439, 1448-49 , 123 L.Ed.2d 1 (1993); In re Individual 35W Bridge Litigation, 806 N.W.2d 820, 830 (Minn.2011).

2013Boutin, 591 N.W.2d at 718 . “[I]f the record indicates that the [statute] is rationally related to achievement of a legitimate governmental purpose, [its application] should be upheld.” Essling v. Markman, 335 N.W.2d 237, 239 (Minn.1983).

1990Essling v. Markman, 335 N.W.2d 237, 239 (Minn.1983).

1993In re Harhut, 385 N.W.2d 305, 310 (Minn.1986).

1986See City of Cleburne v. Cleburne Living Center, — U.S. -, 105 S.Ct. 3249, 3255 , 87 L.Ed.2d 313 (1985); Harhut, supra. When applying the rational basis standard, we make two inquiries: (1) Does the challenged classification have a legitimate purpose? (2) Was it reasonable for lawmakers to believe that use of the challenged classification would promote that purpose?

2006When reviewing municipal land use decisions, we typically utilize a rational basis standard of review. [11] Honn, *180 313 N.W.2d at 414-15 .

2006When reviewing municipal land use decisions, we typically utilize a rational basis standard of review. 11 Honn, 313 N.W.2d at 414-15 .

1987Since parents are presumed to provide proper care, the rationality of excluding care providers who are subject to closer parental supervision is “at least debatable.” See Clover Leaf Creamery Co., 449 U.S. at 464 , 101 S.Ct. at 724 (legislative classification will be upheld under the rational basis test if the rationality of the classification is “at least debatable”).

1987Since parents are presumed to provide proper care, the rationality of excluding care providers who are subject to closer parental supervision is “at least debatable.” See Clover Leaf Creamery Co., 449 U.S. at 464 , 101 S.Ct. at 724 (legislative classification will be upheld under the rational basis test if the rationality of the classification is “at least debatable”).

2012See Gluba, 735 N.W.2d at 719 (stating that when a constitutional challenge does not involve either a suspect class or a fundamental right, the challenge is reviewed using a rational-basis standard).

2012See Gluba, 735 N.W.2d at 719 (stating that when a constitutional challenge does not involve either a suspect class or a fundamental right, the challenge is reviewed using a rational-basis standard).

2006ILHC of Eagan, LLC v. County of Dakota, 693 N.W.2d 412, 421-22 (Minn.2005), quoting Westling v. County of Mille Lacs, 581 N.W.2d 815, 820 (Minn.1998) (when the challenged statute does not involve a suspect classification or a fundamental right, the appropriate standard of review is rational basis).

2006ILHC of Eagan, LLC v. County of Dakota, 693 N.W.2d 412, 421-22 (Minn.2005), quoting Westling v. County of Mille Lacs, 581 N.W.2d 815, 820 (Minn.1998) (when the challenged statute does not involve a suspect classification or a fundamental right, the appropriate standard of review is rational basis).

2015See Reno v. Flores, 507 U.S. 292, 305 , 113 S.Ct. 1439, 1448-49 , 123 L.Ed.2d 1 (1993); In re Individual 35W Bridge Litigation, 806 N.W.2d 820, 830 (Minn.2011).

2015See Reno v. Flores, 507 U.S. 292, 305 , 113 S.Ct. 1439, 1448-49 , 123 L.Ed.2d 1 (1993); In re Individual 35W Bridge Litigation, 806 N.W.2d 820, 830 (Minn.2011).

2014A permit denial is not unreasonable “when at least one of the reasons given for the denial satisfies the rational basis test.” Trisko v. City of Waite Park, 566 N.W.2d 349, 352 (Minn. App. 1997), review denied (Minn. Sept. 25, 1997).

2000The court noted that while some of the other findings were not supported by facts in the record, the Board’s action was valid as long as “ ‘at least one of the reasons given for the denial satisfies the rational basis test.’ ” Id. (quoting Trisko v. City of Waite Park, 566 N.W.2d 349, 352 (Minn.App.), rev. denied (Minn. Sept. 25, 1997)).

2014The rational-basis standard requires that: (1) “the act serve to promote a public purpose,” (2) the act “not be an unreasonable, arbitrary or capricious interference” with a private interest, and (3) “the means chosen bear a rational relation to the public purpose sought to be served.” Contos v. Herbst, 278 N.W.2d 732, 741 (Minn.1979).

1999The rational basis standard requires: (1) that "the act serve to promote a public purpose," (2) that the act "not be an unreasonable, arbitrary or capricious interference" with a private interest, and (3) that "the means chosen bear a rational relation to the public purpose sought to be served." Contos v. Herbst, 278 N.W.2d 732, 741 (Minn.1979).

2007See Erlandson v. Kiffmeyer, 659 N.W.2d 724, 738 (Minn.2003) (stating that to determine whether a statute violates equal protection, this court first examines “whether the challenged classification must satisfy strict scrutiny or merely the rational basis standard.”).

2007See Erlandson v. Kiffmeyer, 659 N.W.2d 724, 733 (Minn.2003) (stating that to determine whether a statute violates equal protection, this court first examines "whether the challenged classification must satisfy strict scrutiny or merely the rational basis standard.").

1990Western & Southern Life Insurance Co. v. State Board of Equalization of California, 451 U.S. 648, 668 , 101 S.Ct. 2070, 2083 , 68 L.Ed.2d 514 (1981); AFSCME Councils, 338 N.W.2d at 570 .

1990Western & Southern Life Insurance Co. v. State Board of Equalization of California, 451 U.S. 648, 668 , 101 S.Ct. 2070, 2083 , 68 L.Ed.2d 514 (1981); AFSCME Councils, 338 N.W.2d at 570 .

1985Thus, her equal protection challenge is subject to review under the rational basis standard. 5 This court has stated that “[t]he standards of the equal protection clause of the fourteenth amendment are synonymous with the standards of equality under Minn. Const, art. 1, § 2 * * *.” State v. Forge, 262 N.W.2d 341 , 347 n. 23 (Minn.1977).

1983See State v. Forge, 262 N.W.2d 341 , 347 n. 23 (Minn.1977); Minneapolis Federation of Teachers Local 59 v. Obermeyer, 275 Minn. 347, 354 , 147 N.W.2d 358, 363 (1966). [12] A recurring expression of this rational basis standard is the following three-part test, which operates to uphold legislative classifications if: (1) the classification uniformly, without discrimination, applies to and embraces all who are similarly situated with respect to conditions or wants justifying appropriate legislation; (2) the distinctions which separate those who are included within the classification from those w

1999Co., 304 U.S. 144 , 153-54, 58 S.Ct. 778 , 82 L.Ed. 1234 (1938) (stating that the rational basis test requires the challenged legislation to be supported by any set of facts either known or which could reasonably be assumed); United States v. Osburn, 955 F.2d 1500, 1505 (11th Cir.) (stating that "any rationale Congress `could' have had for enacting the statute can validate the legislation, regardless *718 of whether Congress actually considered that rationale at the time the bill was passed"), cert. denied, 506 U.S. 878 , 113 S.Ct. 223 , 121 L.Ed.2d 160 (1992).

1999Co., 304 U.S. 144 , 153-54, 58 S.Ct. 778 , 82 L.Ed. 1234 (1938) (stating that the rational basis test requires the challenged legislation to be supported by any set of facts either known or which could reasonably be assumed); United States v. Osburn, 955 F.2d 1500, 1505 (11th Cir.) (stating that “any rationale Congress ‘could’ have had for enacting the statute can validate the legislation, re gardless of whether Congress actually considered that rationale at the time the bill was passed”), cert. denied, 506 U.S. 878 , 113 S.Ct. 223 , 121 L.Ed.2d 160 (1992).

2016Mendota Golf, 708 N.W.2d at 179 .

2007As we noted in Mendota Golf, however, Sun Oil does not articulate a standard of judicial review different from the rational basis standard we apply here. 708 N.W.2d at 180 n. 11 (discussing Sun Oil).

2011Id. at 406 n. 10.

2011Specifically, we cited to McKnight’s discussion of the following cases: Wegan v. Vil lage of Lexington, 309 N.W.2d 273 (Minn.1981), Nelson v. Peterson, 313 N.W.2d 580 (Minn.1981), and Thompson v. Estate of Petroff, 319 N.W.2d 400 (Minn.1982).