substantive due process standard (West Virginia) · Go Syfert
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substantive due process standard in West Virginia

18 West Virginia opinions name it 1 courts 1977–2025 1 in the last five years

The cases below were cited by West Virginia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (11)

CaseFollowedCited
Thorne v. Roushgreen
wva · 1979 · cited in 5 West Virginia opinions naming this issue, 1984–2020
2 sentences

2020The circuit court reasoned that, “[i]n order for a statute to withstand constitutional scrutiny under the substantive due process standard, it must appear that the means chosen by the Legislature to achieve a proper legislative purpose bear a rational relationship to that purpose and are not arbitrary or discriminatory.” Thorne v. Roush, 164 W.

2020The circuit court reasoned that, “[i]n order for a statute to withstand constitutional scrutiny under the substantive due process standard, it must appear that the means chosen by the Legislature to achieve a proper legislative purpose bear a rational relationship to that purpose and are not arbitrary or discriminatory.” Thorne v. Roush, 164 W.

35
State Ex Rel . Harris v. Calendinegreen
wva · 1977 · cited in 5 West Virginia opinions naming this issue, 1982–2009
2 sentences

1984Harris v. Calendine, 160 W.Va. 172, 179 , 233 S.E.2d 318, 324 (1977), this Court stated that “Inherent in the due process clause of the State Constitution are both the concept of substantive due process and the concept of equal protection of the laws.” Later, in Thorne v. Roush, 164 W.Va. 165 , 261 S.E.2d 72, 74 (1979), we stated that “In order for a statute to withstand constitutional scrutiny under the substantive due process standard, it must appear that the means chosen by the Legislature to achieve a proper legislative purpose bear a rational relationship to that purpose and are not arbit

1984Harris v. Calendine, 160 W.Va. 172, 179 , 233 S.E.2d 318, 324 (1977), this Court stated that “Inherent in the due process clause of the State Constitution are both the concept of substantive due process and the concept of equal protection of the laws.” Later, in Thorne v. Roush, 164 W.Va. 165 , 261 S.E.2d 72, 74 (1979), we stated that “In order for a statute to withstand constitutional scrutiny under the substantive due process standard, it must appear that the means chosen by the Legislature to achieve a proper legislative purpose bear a rational relationship to that purpose and are not arbit

35
Lockyer v. Andradegreen
scotus · 2003 · cited in 2 West Virginia opinions naming this issue, 2003–2004
2 sentences

2004As this Court noted in Haislop v. Edgell, 215 W.Va. 88, 99 , 593 S.E.2d 839, 850 [2003] (upholding sex offender registration statute): Additionally, we are not unmindful that the concurring opinion of Justices Souter and Ginsburg in Connecticut Department of Public Safety noted that they "agree with the observation that today's holding does not foreclose a claim that Connecticut's dissemination of registry information is actionable on a substantive due process principle[J” Id. 538 U.S. at 8, 123 S.Ct. at 1165, 155 L.Ed.2d at 106, and that "the Court's rejection of respondents' procedural due p

2004As this Court noted in Haislop v. Edgell, 215 W.Va. 88, 99 , 593 S.E.2d 839, 850 [2003] (upholding sex offender registration statute): Additionally, we are not unmindful that the concurring opinion of Justices Souter and Ginsburg in Connecticut Department of Public Safety noted that they "agree with the observation that today's holding does not foreclose a claim that Connecticut's dissemination of registry information is actionable on a substantive due process principle[,]" Id. 538 U.S. at 8, 123 S.Ct. at 1165, 155 L.Ed.2d at 106, and that "the Court's rejection of respondents' procedural due

22
DeCoals, Inc. v. BD. OF ZONING APPEALS, ETC.green
wva · 1981 · cited in 3 West Virginia opinions naming this issue, 1984–1985
2 sentences

1985The substantive due process standard that we apply to legislative enactments is summarized in Syllabus Point 1 of State v. Wender, 149 W.Va. 413 , 141 S.E.2d 359 (1965), overruled on other grounds, Hartsock-Flesher Candy Co. v. Wheeling Wholesale Grocery Co., 174 W.Va. 538 , 328 S.E.2d 144 (1984): “The legislature is vested with a wide discretion in determining what the public interest requires, the wisdom of which may not be inquired into by the courts; however, to satisfy the requirements of due process of law, legislative acts must bear a reasonable relationship to a proper legislative purp

1985The substantive due process standard that we apply to legislative enactments is summarized in Syllabus Point 1 of State v. Wender, 149 W.Va. 413 , 141 S.E.2d 359 (1965), overruled on other grounds, Hartsock-Flesher Candy Co. v. Wheeling Wholesale Grocery Co., 174 W.Va. 538 , 328 S.E.2d 144 (1984): “The legislature is vested with a wide discretion in determining what the public interest requires, the wisdom of which may not be inquired into by the courts; however, to satisfy the requirements of due process of law, legislative acts must bear a reasonable relationship to a proper legislative purp

13
United States v. Steven Greengreen
ca6 · 2011 · cited in 1 West Virginia opinions naming this issue, 2025–2025
1 sentence

2025Me. 2009) (citation omitted) (“[T]he vindictive prosecution doctrine imposes critical ‘constitutional limits’ upon the exercise of prosecutorial discretion.”). 15 For example, in United States v. Smith, 953 F.2d 1060, 1063 (7th Cir. 1992), the court of appeals explained, “[a]rbitrariness—that is, unjustified disparities in the treatment of similarly situated persons—is not among the grounds on which to contest an exercise of prosecutorial discretion.” See United States v. Green, 654 F.3d 637, 653 (6th Cir. 2011) (observing that Smith stands “for the proposition that an exercise of prosecutoria

11
Oyler v. Bolesgreen
scotus · 1962 · cited in 1 West Virginia opinions naming this issue, 2025–2025
1 sentence

2025Indeed, the United States Supreme Court found in Oyler v. Boles, 368 U.S. 448, 456 (1962) that “the conscious exercise of some selectivity in enforcement [of a recidivist statute] is not in itself a federal constitutional violation.” What does constitute a constitutional violation is the selective exercise of prosecutorial discretion in violation of equal protection.

11
United States v. Jeffrey C. Smithgreen
ca7 · 1992 · cited in 1 West Virginia opinions naming this issue, 2025–2025
1 sentence

2025Me. 2009) (citation omitted) (“[T]he vindictive prosecution doctrine imposes critical ‘constitutional limits’ upon the exercise of prosecutorial discretion.”). 15 For example, in United States v. Smith, 953 F.2d 1060, 1063 (7th Cir. 1992), the court of appeals explained, “[a]rbitrariness—that is, unjustified disparities in the treatment of similarly situated persons—is not among the grounds on which to contest an exercise of prosecutorial discretion.” See United States v. Green, 654 F.3d 637, 653 (6th Cir. 2011) (observing that Smith stands “for the proposition that an exercise of prosecutoria

11
Par Mar v. City of Parkersburggreen
wva · 1990 · cited in 1 West Virginia opinions naming this issue, 2020–2020
1 sentence

2020See id.

11
Haislop v. Edgellgreen
wva · 2003 · cited in 1 West Virginia opinions naming this issue, 2004–2004
2 sentences

2004As this Court noted in Haislop v. Edgell, 215 W.Va. 88, 99 , 593 S.E.2d 839, 850 [2003] (upholding sex offender registration statute): Additionally, we are not unmindful that the concurring opinion of Justices Souter and Ginsburg in Connecticut Department of Public Safety noted that they "agree with the observation that today's holding does not foreclose a claim that Connecticut's dissemination of registry information is actionable on a substantive due process principle[,]" Id. 538 U.S. at 8, 123 S.Ct. at 1165, 155 L.Ed.2d at 106, and that "the Court's rejection of respondents' procedural due

2004As this Court noted in Haislop v. Edgell, 215 W.Va. 88, 99 , 593 S.E.2d 839, 850 [2003] (upholding sex offender registration statute): Additionally, we are not unmindful that the concurring opinion of Justices Souter and Ginsburg in Connecticut Department of Public Safety noted that they "agree with the observation that today's holding does not foreclose a claim that Connecticut's dissemination of registry information is actionable on a substantive due process principle[,]" Id. 538 U.S. at 8, 123 S.Ct. at 1165, 155 L.Ed.2d at 106, and that "the Court's rejection of respondents' procedural due

11
Ingraham v. Wrightgreen
scotus · 1977 · cited in 1 West Virginia opinions naming this issue, 1982–1982
2 sentences

1982See Note 12, Ingraham v. Wright, 430 U.S. at 659 , 97 S.Ct. at 1406 , 51 L.Ed.2d at 723 .

1982See Note 12, Ingraham v. Wright, 430 U.S. at 659 , 97 S.Ct. at 1406 , 51 L.Ed.2d at 723 .

11
In re Ellery C.green
ny · 1973 · cited in 1 West Virginia opinions naming this issue, 1977–1977
1 sentence

1977Chief Judge Fuld noted “as might be expected, the practice [of confining PINS with juvenile delinquents] has been severely condemned.” Id. at 425.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in West Virginia. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
Board of Regents of State Colleges v. Roth green
scotus · 1972
2 sentences

2016The Supreme Court has made clear that property interests are not created by the constitution, itself, but rather by “existing rules or understandings that stem from an independent source such as state law-rules or understandings that secure certain benefits and that support claims of entitlement to those benefits.” Board of Regents v. Roth, 408 U.S. 564, 577 , 92 S. Ct. 2701, 2709 , 33 L.Ed.2d 548 (1972). 2 In the instant proceeding, Pioneer Pipe was granted a statutory right that protected its property from being arbitrarily and capriciously taken by the Insurance Commissioner.

2016The Supreme Court has made clear that property interests are not created by the constitution, itself, but rather by “existing rules or understandings that stem from an independent source such as state law-rules or understandings that secure certain benefits and that support claims of entitlement to those benefits.” Board of Regents v. Roth, 408 U.S. 564, 577 , 92 S. Ct. 2701, 2709 , 33 L.Ed.2d 548 (1972). 2 In the instant proceeding, Pioneer Pipe was granted a statutory right that protected its property from being arbitrarily and capriciously taken by the Insurance Commissioner.

22016–2016
County Concrete Corporation v. Township Of Roxbury green
ca3 · 2006
2 sentences

2016Moreover, in order “[t]o prevail on a substantive due process claim, a plaintiff must demonstrate that an arbitrary and capricious act deprived them of a protected property interest.” County Concrete Corp. v. Town of Roxbury, 442 F.3d 159 , 165 (3d Cir. 2006).

2016Moreover, in order “[t]o prevail on a substantive due process claim, .a plaintiff must demonstrate that an arbitrary and capricious act deprived them of a protected property interest.” County Concrete Corp. v. Town of Roxbury, 442 F.3d 159 , 165 (3d Cir. 2006).

22016–2016
O'NEIL v. City of Parkersburg green
wva · 1977
2 sentences

1985The substantive due process standard that we apply to legislative enactments is summarized in Syllabus Point 1 of State v. Wender, 149 W.Va. 413 , 141 S.E.2d 359 (1965), overruled on other grounds, Hartsock-Flesher Candy Co. v. Wheeling Wholesale Grocery Co., 174 W.Va. 538 , 328 S.E.2d 144 (1984): “The legislature is vested with a wide discretion in determining what the public interest requires, the wisdom of which may not be inquired into by the courts; however, to satisfy the requirements of due process of law, legislative acts must bear a reasonable relationship to a proper legislative purp

1985The substantive due process standard that we apply to legislative enactments is summarized in Syllabus Point 1 of State v. Wender, 149 W.Va. 413 , 141 S.E.2d 359 (1965), overruled on other grounds, Hartsock-Flesher Candy Co. v. Wheeling Wholesale Grocery Co., 174 W.Va. 538 , 328 S.E.2d 144 (1984): “The legislature is vested with a wide discretion in determining what the public interest requires, the wisdom of which may not be inquired into by the courts; however, to satisfy the requirements of due process of law, legislative acts must bear a reasonable relationship to a proper legislative purp

21984–1985
State v. Wender green
wva · 1965
2 sentences

1985The substantive due process standard that we apply to legislative enactments is summarized in Syllabus Point 1 of State v. Wender, 149 W.Va. 413 , 141 S.E.2d 359 (1965), overruled on other grounds, Hartsock-Flesher Candy Co. v. Wheeling Wholesale Grocery Co., 174 W.Va. 538 , 328 S.E.2d 144 (1984): “The legislature is vested with a wide discretion in determining what the public interest requires, the wisdom of which may not be inquired into by the courts; however, to satisfy the requirements of due process of law, legislative acts must bear a reasonable relationship to a proper legislative purp

1985The substantive due process standard that we apply to legislative enactments is summarized in Syllabus Point 1 of State v. Wender, 149 W.Va. 413 , 141 S.E.2d 359 (1965), overruled on other grounds, Hartsock-Flesher Candy Co. v. Wheeling Wholesale Grocery Co., 174 W.Va. 538 , 328 S.E.2d 144 (1984): “The legislature is vested with a wide discretion in determining what the public interest requires, the wisdom of which may not be inquired into by the courts; however, to satisfy the requirements of due process of law, legislative acts must bear a reasonable relationship to a proper legislative purp

21984–1985
State v. Lilly green
wva · 1995
2 sentences

2020However, petitioners have not squarely addressed a substantive due process issue and “‘[w]e have noted on many occasions that “casual mention of an issue in a brief is cursory treatment insufficient to preserve the issue on appeal.’ State v. Lilly, 194 W.Va. 595 , 605 n. 16, 461 S.E.2d 101 , 111 n. 16 (1995).” State v. Lambert, 236 W.

2020However, petitioners have not squarely addressed a substantive due process issue and “‘[w]e have noted on many occasions that “casual mention of an issue in a brief is cursory treatment insufficient to preserve the issue on appeal.’ State v. Lilly, 194 W.Va. 595 , 605 n. 16, 461 S.E.2d 101 , 111 n. 16 (1995).” State v. Lambert, 236 W.

12020–2020
State of West Virginia v. Jeremy Lambert green
wva · 2015
1 sentence

2020However, petitioners have not squarely addressed a substantive due process issue and “‘[w]e have noted on many occasions that “casual mention of an issue in a brief is cursory treatment insufficient to preserve the issue on appeal.’ State v. Lilly, 194 W.Va. 595 , 605 n. 16, 461 S.E.2d 101 , 111 n. 16 (1995).” State v. Lambert, 236 W.

12020–2020
State v. Whalen green
wva · 2003
2 sentences

2003Additionally, we are not unmindful that the concurring opinion of Justices Souter and Ginsburg in Connecticut Department of Public Safety noted that they "agree with the observation that today's holding does not foreclose a claim that Connecticut's dissemination of registry information is actionable on a substantive due process principle[,]" Id. 538 U.S. at 8, 123 S.Ct. at 1165, 155 L.Ed.2d at 106, and that "the Court's rejection of respondents' procedural due process claim does not immunize publication schemes like Connecticut's from an equal protection challenge." Id. 538 U.S. at 10, 123 S.C

2003Additionally, we are not unmindful that the concurring opinion of Justices Souter and Ginsburg in Connecticut Department of Public Safety noted that they “agree with the observation that today’s holding does not foreclose a claim that Connecticut’s dissemination of registry information is actionable on a substantive due process principle!!,]” Id. 538 U.S. at 8, 123 S.Ct. at 1165, 155 L.Ed.2d at 106, and that “the Court’s rejection of respondents’ procedural due process claim does not immunize publication schemes like Connecticut’s from an equal protection challenge.” Id. 538 U.S. at 10, 123 S.

12003–2003
Simpson v. Pittsburgh Corning Corporation green
ca2 · 1990
1 sentence

1992We, therefore, find ourselves in much the same position as the Court of Appeals for the Second Circuit did in Simpson v. Pittsburgh Corning Corp., 901 F.2d at 282 , when confronted with the same substantive due process argument: “In more recent encounters with the issue, we have concluded that the substantive due process claim was neither adequately raised, Racich v. Celotex Corp., 887 F.2d [393] 398 [(2d Cir.1989)], nor factually supported in the district court, Johnson v. Celotex Corp., 899 F.2d [1281] 1288 [(2d Cir.1990)]; Racich v. Celotex Corp., 887 F.2d at 398.

11992–1992
Hartsock-Flesher Candy Co. v. Wheeling Wholesale Grocery Co. green
wva · 1984
2 sentences

1985The substantive due process standard that we apply to legislative enactments is summarized in Syllabus Point 1 of State v. Wender, 149 W.Va. 413 , 141 S.E.2d 359 (1965), overruled on other grounds, Hartsock-Flesher Candy Co. v. Wheeling Wholesale Grocery Co., 174 W.Va. 538 , 328 S.E.2d 144 (1984): “The legislature is vested with a wide discretion in determining what the public interest requires, the wisdom of which may not be inquired into by the courts; however, to satisfy the requirements of due process of law, legislative acts must bear a reasonable relationship to a proper legislative purp

1985The substantive due process standard that we apply to legislative enactments is summarized in Syllabus Point 1 of State v. Wender, 149 W.Va. 413 , 141 S.E.2d 359 (1965), overruled on other grounds, Hartsock-Flesher Candy Co. v. Wheeling Wholesale Grocery Co., 174 W.Va. 538 , 328 S.E.2d 144 (1984): “The legislature is vested with a wide discretion in determining what the public interest requires, the wisdom of which may not be inquired into by the courts; however, to satisfy the requirements of due process of law, legislative acts must bear a reasonable relationship to a proper legislative purp

11985–1985
Wyatt v. Stickney green
almd · 1971
1 sentence

1977The Court said at 202 S.E.2d 120 : “The theoretical beneficence of the State with regard to its citizens has been used in justification of state custody or guardianship from the medieval period to our own day, although the disparity between the theory of beneficence and the practice of cruelty and inhumanity has often been the subject of literature (see, Dickens, Oliver Twist; Bronte, Jane Eyre.) There is persuasive evidence that the alleged improvement in treatment in modern state facilities from medieval times to our own is more myth than reality, see, Wyatt v. Stickney, 325 F. Supp. 781 (D.

11977–1977

Statutes the citing opinions construe

USC § 29u.s.c.151 (3) WV § W. Va. Code § 30-27-3 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 114 (1981–2026) IL 110 (1980–2026) TX 110 (1987–2025) PA 103 (1973–2026) WA 102 (1987–2024) IA 60 (1983–2024) MI 57 (1986–2025) WI 49 (1989–2024) NY 43 (1975–2026) NJ 38 (1970–2025) FL 34 (1974–2025) CT 31 (1991–2020) MN 30 (1986–2024) OH 28 (1989–2025) MA 25 (1975–2025) AL 24 (1980–2025) RI 23 (1991–2020) CO 22 (1960–2026) MD 21 (1985–2024) ND 21 (1978–2025) ME 20 (1981–2022) MS 18 (1991–2022) AZ 18 (1991–2023) WV 18 (1977–2025) UT 16 (1989–2026) SC 15 (1993–2025) MO 14 (1989–2023) KS 14 (1968–2025) GA 13 (1983–2021) TN 13 (1993–2018) AK 13 (1995–2025) NM 12 (1989–2025) NC 12 (1976–2021) VA 11 (1989–2025) OK 11 (1984–2022) DC 10 (1987–2023) NH 10 (1993–2015) MT 9 (1981–2025) LA 9 (1997–2024) ID 9 (1986–2023) IN 8 (1994–2024) SD 8 (1996–2024) WY 8 (1989–2026) DE 8 (1989–2025) NV 8 (1980–2025) AR 7 (2004–2023) OR 6 (1974–2011) KY 3 (2003–2025) HI 3 (1992–2018) NE 3 (1994–2025) VI 2 (2011–2015)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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