rational basis test in Indiana

2016The government need not prove the reason to a court’s satisfaction.” Northside Sanitary Landfill, Inc. v. City of Indianapolis, 902 F.2d 521, 522 (7th Cir.1990) (citations omitted).

2003The government need not prove the reason to a court's satisfaction."" N.B. v. Sybinski, 724 N.E.2d 1103, 1112 (Ind.Ct.App.2000) (quoting Northside Sanitary Landfill, Inc. v. City of Indianapolis, 902 F.2d 521, 522 (7th Cir.1990)), trans. denied; see also FCC v. Beach Communications, Inc., 508 U.S. at 315 , 113 S.Ct. 2096 ("a legislative choice is not subject to courtroom fact-finding and may be based on rational speculation unsupported by evidence or empirical data"); Crafton v. Gibson, 752 N.E.2d 78 (Ind.Ct.App.2001).

2001See N.B. v. Sybinski, 724 N.E.2d 1103, 1112 (Ind.Ct.App.2000), trans. denied. "[Slubstantive due process [is] the constitutional doctrine of implementation by courts of the 'promise of the Constitution that there is a realm of personal liberty which the government may not enter.! " Indiana High School Athletic Ass'n, Inc. v. Schafer, 598 N.E.2d 540, 551 (Ind.Ct.App.1992) (citing Planned Parenthood of S.E.

1992Thomas, however, relies upon Sturrup v. Mahan (1974), 261 Ind. 463 , 305 N.E.2d 877 and the recent case of IHSAA v. Schafer (1992) Ind.App., 598 N.E.2d 540 for the proposition that something more than the traditional rational basis test is called for when reviewing IHSAA rules.

2019“Ordinary government activities” that do not infringe on fundamental rights, on the other hand, “must only satisfy a rational basis test, which requires merely that the law be ‘rationally related to a legitimate governmental purpose.’” Id. (quoting Clark, 486 U.S. at 461 ). [13] Our Court has held that the “state and federal substantive due process analys[e]s [are] identical.” N.B., 724 N.E.2d at 1112 .

1994Ordinary government activities must only satisfy a rational basis test, which requires merely that the law be "rationally related to a legitimate governmental purpose." Clark v. Jeter, 486 U.S. 456, 461 , 108 S.Ct. 1910, 1914 , 100 L.Ed.2d 465, 471 (1988).

2019“Ordinary government activities” that do not infringe on fundamental rights, on the other hand, “must only satisfy a rational basis test, which requires merely that the law be ‘rationally related to a legitimate governmental purpose.’” Id. (quoting Clark, 486 U.S. at 461 ). [13] Our Court has held that the “state and federal substantive due process analys[e]s [are] identical.” N.B., 724 N.E.2d at 1112 .

2003The government need not prove the reason to a court's satisfaction."" N.B. v. Sybinski, 724 N.E.2d 1103, 1112 (Ind.Ct.App.2000) (quoting Northside Sanitary Landfill, Inc. v. City of Indianapolis, 902 F.2d 521, 522 (7th Cir.1990)), trans. denied; see also FCC v. Beach Communications, Inc., 508 U.S. at 315 , 113 S.Ct. 2096 ("a legislative choice is not subject to courtroom fact-finding and may be based on rational speculation unsupported by evidence or empirical data"); Crafton v. Gibson, 752 N.E.2d 78 (Ind.Ct.App.2001).

2012Bennett v. State, 801 N.E.2d 170, 175 (Ind.Ct.App.2003).

2010See id.

2015See Cottingham v. State, 424 N.E.2d 105 (Ind. 1981).

2000Under a rational basis test, the question is "only whether the distinction between inmates rationally furthers some legitimate, articulate state purpose." Id. at 107 (quoting McGinnis v. Royster, 410 U.S. 263, 269-270 , 93 S.Ct. 1055, 1059 , 35 L.Ed.2d 282 (1973)).

2002State v. Alcorn, 638 N.E.2d 1242 (Ind.1994).

2001State v. Alcorn, 638 N.E.2d 1242, 1244 (Ind.1994).

2011Beach Communications, 508 U.S. at 314 , 113 S.Ct. 2096 (citation omitted); see also Nordlinger, 505 U.S. at 10 , 112 S.Ct. 2326 (“ ‘[Legislatures are presumed to have acted within their constitutional power despite the fact that, in practice, their laws result in some inequality.’ ” (alteration added) (quoting McGowan v. Maryland, 366 U.S. 420, 425-26 , 81 S.Ct. 1101 , 6 L.Ed.2d 393 (1961))).

2011Beach Communications, 508 U.S. at 314 , 113 S.Ct. 2096 (citation omitted); see also Nordlinger, 505 U.S. at 10 , 112 S.Ct. 2326 (“ ‘[Legislatures are presumed to have acted within their constitutional power despite the fact that, in practice, their laws result in some inequality.’ ” (alteration added) (quoting McGowan v. Maryland, 366 U.S. 420, 425-26 , 81 S.Ct. 1101 , 6 L.Ed.2d 393 (1961))).

2008We will apply a rational basis analysis except where the classification is suspect or involves fundamental rights.” Schnitz, 650 N.E.2d at 725 .

2001Schnitz v. State, 650 N.E.2d 717, 725 (Ind.Ct.App.1995), aff'd by 666 N.E.2d 919 (Ind.1996).

2007Athletic Ass'n, Inc. v. Carlberg by Carlberg, 694 N.E.2d 222, 236 (Ind.1997) ( quoting Clark v. Jeter, 486 U.S. 456, 461 , 108 S.Ct. 1910 , 100 L.Ed.2d 465 (1988)).

2007Athletic Ass’n, Inc. v. Carlberg by Carlberg, 694 N.E.2d 222, 236 (Ind.1997) (quoting Clark v. Jeter, 486 U.S. 456, 461 , 108 S.Ct. 1910 , 100 L.Ed.2d 465 (1988)).

1997If the classification involves neither a suspect class nor a fundamental right, the level of scrutiny used is the rational basis test, that is, “the legislation will pass constitutional muster if the classification is ‘rationally related to a legitimate government purpose.’ ” Id. (quoting Pazzaglia v. Review Bd., 608 N.E.2d 1375, 1377 (Ind.Ct.App.1993), trans. denied).

1995Id.

1992As stated in Sobieralski v. South Bend (1985), Ind.App., 479 N.E.2d 98, 100 , reh. denied, trans. denied: The rational basis test is an inquiry which involves a relatively relaxed standard, reflecting the judiciary's awareness that there can be no perfection in legislative classification, and that the drawing of lines creates unavoidable distinctions.

1992As stated in Sobieralski v. South Bend (1985), Ind.App., 479 N.E.2d 98, 100 , reh. denied, trans. denied: The rational basis test is an inquiry which involves a relatively relaxed standard, reflecting the judiciary's awareness that there can be no perfection in legislative classification, and that the drawing of lines creates unavoidable distinctions.

1980The court held that the rational basis test was the appropriate standard as set forth in United States v. Carolene Products, 304 U.S. 144 , 58 S.Ct. 778 , 82 L.Ed.2d 1234 (1938) as follows: Where the existence of a rational basis for legislation whose constitutionality is attacked depends upon facts beyond the sphere of judicial notice, such facts may properly be made the subject of judicial inquiry, and the constitutionality of a statute predicated upon the existence of a particular state of facts may be challenged by showing to the court that those facts have ceased to exist. . . .

1980The court held that the rational basis test was the appropriate standard as set forth in United States v. Carolene Products, 304 U.S. 144 , 58 S.Ct. 778 , 82 L.Ed.2d 1234 (1938) as follows: Where the existence of a rational basis for legislation whose constitutionality is attacked depends upon facts beyond the sphere of judicial notice, such facts may properly be made the subject of judicial inquiry, and the constitutionality of a statute predicated upon the existence of a particular state of facts may be challenged by showing to the court that those facts have ceased to exist. . . .

2016(See, e.g., AK Steel’s Br. at-28; AK-Steel’s Reply Br. at 21 (stating that the Legislature’s “economic protectionist goal” in adopting the “in Indiana” language is “invidious and irrational”).) See also Coniston Corp. v. Vill. of Hoffman Estates, 844 F.2d 461, 467 (7th Cir.1988) (explaining that, “arbitrary and unreasonable” has been interpreted to mean invidious or irrational). "[G]overnmental action passes the rational basis test if a sound reason may be hypothesized.

2012Fancher v. State, 918 N.E.2d 16, 20 (Ind.Ct.App.2009).

2011Beach Communications, 508 U.S. at 314 , 113 S.Ct. 2096 (citation omitted); see also Nordlinger, 505 U.S. at 10 , 112 S.Ct. 2326 (“ ‘[Legislatures are presumed to have acted within their constitutional power despite the fact that, in practice, their laws result in some inequality.’ ” (alteration added) (quoting McGowan v. Maryland, 366 U.S. 420, 425-26 , 81 S.Ct. 1101 , 6 L.Ed.2d 393 (1961))).

2011Beach Communications, 508 U.S. at 314 , 113 S.Ct. 2096 (citation omitted); see also Nordlinger, 505 U.S. at 10 , 112 S.Ct. 2326 (“ ‘[Legislatures are presumed to have acted within their constitutional power despite the fact that, in practice, their laws result in some inequality.’ ” (alteration added) (quoting McGowan v. Maryland, 366 U.S. 420, 425-26 , 81 S.Ct. 1101 , 6 L.Ed.2d 393 (1961))).

2011Beach Communications, 508 U.S. at 314 , 113 S.Ct. 2096 (citation omitted); see also Nordlinger, 505 U.S. at 10 , 112 S.Ct. 2326 (“ ‘[Legislatures are presumed to have acted within their constitutional power despite the fact that, in practice, their laws result in some inequality.’ ” (alteration added) (quoting McGowan v. Maryland, 366 U.S. 420, 425-26 , 81 S.Ct. 1101 , 6 L.Ed.2d 393 (1961))).

2011Beach Communications, 508 U.S. at 314 , 113 S.Ct. 2096 (citation omitted); see also Nordlinger, 505 U.S. at 10 , 112 S.Ct. 2326 (“ ‘[Legislatures are presumed to have acted within their constitutional power despite the fact that, in practice, their laws result in some inequality.’ ” (alteration added) (quoting McGowan v. Maryland, 366 U.S. 420, 425-26 , 81 S.Ct. 1101 , 6 L.Ed.2d 393 (1961))).

2010Poling v. State, 740 N.E.2d 872, 885 (Ind.Ct.App.2000), overruled on other grounds by Graves v. State, 823 N.E.2d 1193 (Ind.2005).