rational basis test in Kansas

2022See Peden v. State, 261 Kan. 239, 258 , 930 P.2d 1 (1996) ("The rational basis standard is a very lenient standard.

2022All the court must do to uphold a legislative classification under the rational basis standard is perceive any state of facts which rationally justifies the classification." Peden, 261 Kan. at 258 .

2013A statute or regulation fails the rational basis test only if the classification at issue “ Tests on grounds wholly irrelevant to the achievement of the State’s legitimate objective.’ ” Weisgerber, 285 Kan. at 105 (quoting Leiker v. Gafford, 245 Kan. 325, 363-64 , 778 P.2d 823 [1989]).

2013A statute or regulation fails the rational basis test only if the classification at issue “ Tests on grounds wholly irrelevant to the achievement of the State’s legitimate objective.’ ” Weisgerber, 285 Kan. at 105 (quoting Leiker v. Gafford, 245 Kan. 325, 363-64 , 778 P.2d 823 [1989]).

2019"Federal and Kansas courts have long delineated three levels of scrutiny in equal protection cases: (1) the rational basis test to determine whether a statutory classification bears some reasonable relationship to a valid legislative purpose; (2) the heightened scrutiny test to determine whether a statutory classification substantially furthers a legitimate legislative purpose; and (3) the strict scrutiny test to determine whether a statutory classification is necessary to serve some compelling State interest." In re Tax Appeals of CIG Field Services Co. , 279 Kan. 857 , 878, 112 P.3d 138 (200

2019"Federal and Kansas courts have long delineated three levels of scrutiny in equal protection cases: (1) the rational basis test to determine whether a statutory classification bears some reasonable relationship to a valid legislative purpose; (2) the heightened scrutiny test to determine whether a statutory classification substantially furthers a legitimate legislative purpose; and (3) the strict scrutiny test to determine whether a statutory classification is necessary to serve some compelling State interest." In re Tax Appeals of CIG Field Services Co. , 279 Kan. 857 , 878, 112 P.3d 138 (200

1997Under the rational basis test, a legislative classification “ ‘must bear a rational relationship to a legitimate objective.’ ” Jurado, 253 *971 Kan. at 123 (quoting Stephenson v. Sugar Creek Packing, 250 Kan. 768, 774 , 830 P.2d 41 [1992]).

1997Under the rational basis test, a legislative classification “ ‘must bear a rational relationship to a legitimate objective.’ ” Jurado, 253 *971 Kan. at 123 (quoting Stephenson v. Sugar Creek Packing, 250 Kan. 768, 774 , 830 P.2d 41 [1992]).

2022When a party challenges a statute as facially unconstitutional under the rational-basis standard, that party bears the burden of proving no rational basis exists that could support the classification. 294 Kan. 188 , Syl. ¶ 10.

2013See In re Tax Appeal of Weisgerber, 285 Kan. 98, 104 , 169 P.3d 321 (2007) (when complaint is that a law causes economic disparity, the rational basis test or “reasonable basis test” is used to determine if tire law violates the Equal Protection Clause); see also Downtown Bar and Grill v. State, 294 Kan. 188, 194 , 273 P.3d 709 (2012) (if legislative classification does not target a suspect class or burden a fundamental right, court applies rational basis test).

2018As stated in Bonin v. Vannaman , 261 Kan. 199 , 217, 929 P.2d 754 (1996) : "The first question in a due process analysis is whether there is a significant public interest to justify [the statutory *248 amendment] and whether this [amendment] has a real and substantial relation to the objective sought." Our Supreme Court has explained that this step in the analysis "is similar to a rational basis test." Lemuz , 261 Kan. at 949 , 933 P.2d 134 .

2018As stated in Bonin v. Vannaman , 261 Kan. 199 , 217, 929 P.2d 754 (1996) : "The first question in a due process analysis is whether there is a significant public interest to justify [the statutory *248 amendment] and whether this [amendment] has a real and substantial relation to the objective sought." Our Supreme Court has explained that this step in the analysis "is similar to a rational basis test." Lemuz , 261 Kan. at 949 , 933 P.2d 134 .

2024See State v. Huerta, 291 Kan. 831, 834 , 247 P.3d 1043 (2011).

2024See State v. Huerta, 291 Kan. 831, 834 , 247 P.3d 1043 (2011).

2026See Crawford v. Kansas Dept. of Revenue, 46 Kan.

2024App. 2d at 575-76. 40 The Spilman panel refused to consider the defendant's claim under the Equal Protection Clause for the same reason, finding his equal protection claim requires additional fact-finding by invoking rational basis scrutiny: "Under the rational basis test, similarly situated individuals may be treated differently without violating equal protection so long as the classification used to distinguish them bears a rational relationship to a legitimate governmental objective. '[A] classification will survive a challenge based on equal protection "if there is any reasonably conceivab

2021"In regard to the first step . . . an individual complaining of an equal protection violation has the burden to demonstrate that he or she is 'similarly situated' to other individuals who are being treated differently [by the Legislature.] [Citations omitted.]" State v. Salas, 289 Kan. 245, 248-49 , 210 P.3d 635 (2009).

2021"In regard to the first step . . . an individual complaining of an equal protection violation has the burden to demonstrate that he or she is 'similarly situated' to other individuals who are being treated differently [by the Legislature.] [Citations omitted.]" State v. Salas, 289 Kan. 245, 248-49 , 210 P.3d 635 (2009).

1997Stephens, 230 Kan. at 130 ; see Ernest, 237 Kan. at 129-30 .

1997Stephens, 230 Kan. at 130 ; see Ernest, 237 Kan. at 129-30 .

2012There are nuances in any equal protection analysis, even under rational basis.” It proceeds to assert that “rational” means “logical,” and not just “any speculative zany idea that the legislature may have had in mind.” Downtown Bar further argues that “as demonstrated in [Farley v.] Engelken [ 241 Kan. 663 , 740 P.2d 1058 (1987)], rational *194 basis is not a 'toothless remedy.’ If it is interpreted to mean just any basis at all, it is a meaningless concept.” (Emphasis added.) We agree that the appropriate standard is the rational basis test.

2012There are nuances in any equal protection analysis, even under rational basis.” It proceeds to assert that “rational” means “logical,” and not just “any speculative zany idea that the legislature may have had in mind.” Downtown Bar further argues that “as demonstrated in [Farley v.] Engelken [ 241 Kan. 663 , 740 P.2d 1058 (1987)], rational *194 basis is not a 'toothless remedy.’ If it is interpreted to mean just any basis at all, it is a meaningless concept.” (Emphasis added.) We agree that the appropriate standard is the rational basis test.

2012We have recognized that the rational basis standard is a “very lenient standard.” Peden v. Kansas Dept. of Revenue, 261 Kan. 239, 258 , 930 P.2d 1 (1996), cert. denied 520 U.S. 1229 (1997).

2011Instead, a party "asserting the unconstitutionality of a statute under the rational basis standard `ha[s] the burden "to negative every conceivable basis which might support [the classification]."' [Citations omitted.]" Peden v. Kansas Dept. of Revenue, 261 Kan. 239, 253 , 930 P.2d 1 (1996), cert. denied 520 U.S. 1229 , 117 S.Ct. 1821 , 137 L.Ed.2d 1029 (1997); see Barrett v. U.S.D.

2002Perez, 269 Kan. at 342 . “ The rational-basis test contains two substantive limitations on legislative choice: legislative enactments must implicate legitimate goals, and the means chosen by the legislature must bear a rational relationship to those goals.’ [Citations omitted.]” Chiles, 254 Kan. at 892 .

1997In Chiles , the court held that the constitutionality of the KSGA must be reviewed under a rational basis standard. 254 Kan. at 899-900 .

2012Instead, a party ‘asserting the unconstitutionality of a statute under the rational basis standard “ha[s] the burden ‘to negative every conceivable basis which might support [the classification].’ ” ’ [Citations omitted.]” (Emphasis added.) As the United States Supreme Court has succinctly explained: “A statutory discrimination will not be set aside if any state of facts reasonably may be conceived to justify it.” McGowan v. Maryland, 366 U.S. 420, 426 , 81 S. Ct. 1101 , 6 L.

2012Instead, a party ‘asserting the unconstitutionality of a statute under the rational basis standard “ha[s] the burden ‘to negative every conceivable basis which might support [the classification].’ ” ’ [Citations omitted.]” (Emphasis added.) As the United States Supreme Court has succinctly explained: “A statutory discrimination will not be set aside if any state of facts reasonably may be conceived to justify it.” McGowan v. Maryland, 366 U.S. 420, 426 , 81 S. Ct. 1101 , 6 L.

2021The general rule is that a law will be subject to the rational basis test unless the legislative classification targets a suspect class or burdens a fundamental right. [Citations omitted.]" State v. Limon, 280 Kan. 275, 283-84 , 122 P.3d 22 (2005).

2021The general rule is that a law will be subject to the rational basis test unless the legislative classification targets a suspect class or burdens a fundamental right. [Citations omitted.]" State v. Limon, 280 Kan. 275, 283-84 , 122 P.3d 22 (2005).

2022App. 2d at 134-35. "'[U]nder the rational basis test, "a law is constitutional, despite some unequal classification of citizens, if the 'classification bears some reasonable relationship to a valid legislative objective.'"'" Denney, 278 Kan. at 651 .

2022To survive the rational basis test the statute "'must meet a two-part test: (1) It must implicate legitimate goals, and (2) the means chosen by the legislature must bear a rational relationship to those goals.'" Denney, 278 Kan. at 651 .

2022All the court must do to uphold a legislative classification under the rational basis standard is perceive any state of facts which rationally justifies the classification."); see also F.C.C. v. Beach Communications, Inc., 508 U.S. 307, 313, 315 , 113 S. Ct. 2096 , 124 L.

2022All the court must do to uphold a legislative classification under the rational basis standard is perceive any state of facts which rationally justifies the classification."); see also F.C.C. v. Beach Communications, Inc., 508 U.S. 307, 313, 315 , 113 S. Ct. 2096 , 124 L.

2019Federal and Kansas courts have long delineated three levels of scrutiny in equal protection cases: (1) the rational basis standard to determine whether a statutory classification bears some rational relationship to a valid legislative purpose; (2) the heightened or intermediate scrutiny standard to determine whether a statutory classification substantially furthers a legitimate legislative purpose; and (3) the strict scrutiny standard to determine whether a statutory classification is necessary to serve some compelling state interest. . . . 25 "The final step of the analysis requires determini

2019Federal and Kansas courts have long delineated three levels of scrutiny in equal protection cases: (1) the rational basis standard to determine whether a statutory classification bears some rational relationship to a valid legislative purpose; (2) the heightened or intermediate scrutiny standard to determine whether a statutory classification substantially furthers a legitimate legislative purpose; and (3) the strict scrutiny standard to determine whether a statutory classification is necessary to serve some compelling state interest. . . . 25 "The final step of the analysis requires determini

2022But G.J.'s burden under the rational basis test is to "negative every conceivable basis which might support it." Madden v. Kentucky, 309 U.S. 83, 88 , 60 S. Ct. 406 , 84 L.

2022But G.J.'s burden under the rational basis test is to "negative every conceivable basis which might support it." Madden v. Kentucky, 309 U.S. 83, 88 , 60 S. Ct. 406 , 84 L.

2022While the rational basis test is a "'very lenient standard,' it is not a 'toothless' one." State v. Cheeks, 298 Kan. 1, 8 , 310 P.3d 346 (2013), overruled on other grounds by State v. LaPointe, 309 Kan. 299 , 434 P.3d 850 (2019).

2022While the rational basis test is a "'very lenient standard,' it is not a 'toothless' one." State v. Cheeks, 298 Kan. 1, 8 , 310 P.3d 346 (2013), overruled on other grounds by State v. LaPointe, 309 Kan. 299 , 434 P.3d 850 (2019).