rational basis test in Hawaii

2024State v. Mallan, 86 Hawai‘i 440, 452, 950 P.2d 178, 190 (1998) (“[T]he police power issue is subsumed within the rational basis test.

2008Consequently, inasmuch as this court's inquiry under a rational basis test "seeks only to determine whether any reasonable justification can be found for the legislative enactment," State v. Mallan, 86 Hawai`i 440, 446, 950 P.2d 178, 184 (1998), and the construction of a bypass road is a reasonable justification for the use of eminent domain, I would hold that the trial court correctly concluded that "County Resolution 31-03 is valid." [3] The majority concludes that the trial court was required to examine the appellants' pretext defense because "both Ajimine and Kelo make it apparent that, al

2024The Time Share Classification and Its Rate Do Not Violate the Equal Protection Clauses of the Hawai‘i and U.S. Constitutions “In analyzing alleged equal protection violations, classifications that are neither suspect nor quasi-suspect are subject to the rational basis test.” Del Rio v. Crake, 87 Hawai‘i 297, 304, 955 P.2d 90, 97 (1998) (internal quotations omitted).

2024Addressing a similar argument in West Maui Resort Partners, the supreme court reiterated the applicable constitutional standard: "In analyzing alleged equal protection violations, classifications that are neither suspect nor quasi-suspect are subject to the rational basis test." Del Rio v. Crake, 87 Hawai#i 297, 304, 955 P.2d 90, 97 (1998) (internal quotations omitted).

2005“Under the rational basis test, we inquire as to whether [HRS § 666-21] rationally furthers a legitimate state interest.” Id. at 572, 852 P.2d at 64 .

2005Baehr, 74 Haw. at 572 , 852 P.2d at 64 (“Under the rational basis test, we inquire as to whether a statute rationally furthers a legitimate state interest.

2024See Nagle v. Bd. of Educ., 63 Haw. 389, 393 , 629 P.2d 109, 112 , (1981) ("Where 'suspect' classifications or fundamental rights are not at issue, this court has traditionally employed the rational basis test." (citation omitted)). (2) The McDermotts argue that the Circuit Court erred in determining that the political question doctrine bars the 4 McDermotts from challenging the State's budgetary and funding decisions and the Legislature's determination of funds appropriated for renovations to Campbell High School.

2024See Nagle v. Bd. of Educ., 63 Haw. 389, 393 , 629 P.2d 109, 112 , (1981) ("Where 'suspect' classifications or fundamental rights are not at issue, this court has traditionally employed the rational basis test." (citation omitted)). (2) The McDermotts argue that the Circuit Court erred in determining that the political question doctrine bars the 4 McDermotts from challenging the State's budgetary and funding decisions and the Legislature's determination of funds appropriated for renovations to Campbell High School.

2019The rational basis standard of review applies here because Tax Foundation does not allege that either a fundamental right or a suspect classification is implicated. 41 Under rational basis review, "[t]he test of constitutionality is whether that statute has a rational relation to a legitimate state interest." Maeda v. Amemiya , 60 Haw. 662 , 669, 594 P.2d 136 , 141 (1979) (citations omitted).

2019The rational basis standard of review applies here because Tax Foundation does not allege that either a fundamental right or a suspect classification is implicated. 41 Under rational basis review, "[t]he test of constitutionality is whether that statute has a rational relation to a legitimate state interest." Maeda v. Amemiya , 60 Haw. 662 , 669, 594 P.2d 136 , 141 (1979) (citations omitted).

1998“Under the rational basis test, we inquire as to whether a statute rationally furthers a legitimate state interest.” Estate of Coates v. Pacific Engineering, 71 Haw. 358, 364 , 791 P.2d 1257, 1260 (1990).

1998“Under the rational basis test, we inquire as to whether a statute rationally furthers a legitimate state interest.” Estate of Coates v. Pacific Engineering, 71 Haw. 358, 364 , 791 P.2d 1257, 1260 (1990).

2008Likewise, in HFDC, this court observed that the appropriate test for determining "public use" in an eminent domain action under both the Hawai`i and United States Constitutions "is substantially the same as the least demanding level of equal protection analysis—`rational basis,'" 79 Hawai`i at 86, 898 P.2d at 598 : Under the rational basis test, the court essentially asks whether a statute rationally furthers a legitimate state interest.

2008Application of the Rational-Basis Test Under a rational basis analysis, this court "essentially asks whether [the legislation] rationally furthers a legitimate [government] interest." Id. at 86, 898 P.2d at 598 .

1990State v. Cotton, 55 Haw. 148, 150 , 516 P.2d 715, 717 (1973); State v. Johnston, 51 Haw. 195, 203 , 456 P.2d 805, 810 (1969).

1990State v. Cotton, 55 Haw. 148, 150 , 516 P.2d 715, 717 (1973); State v. Johnston, 51 Haw. 195, 203 , 456 P.2d 805, 810 (1969).

1990State v. Cotton, 55 Haw. 148, 150 , 516 P.2d 715, 717 (1973); State v. Johnston, 51 Haw. 195, 203 , 456 P.2d 805, 810 (1969).

1990State v. Cotton, 55 Haw. 148, 150 , 516 P.2d 715, 717 (1973); State v. Johnston, 51 Haw. 195, 203 , 456 P.2d 805, 810 (1969).

1981As the United States Supreme Court has pointed out, a statute which is being analyzed under the rational basis standard need not provide the perfect solution to a problem: If the classification has some “reasonable basis,” it does not offend the Constitution simply because the classification “is not made with mathematical nicety or because in practice it results in some inequality.” Dandridge v. Williams, supra at 485, citing Lindsley v. Natural Carbonic Gas Co., 220 U.S. 61, 78 (1911). *397 In addition, we do not share appellants’ position that this court has broad discretion in this case to

1972Judgment affirmed. 1 For a post Shapiro v. Thompson utilization of the traditional rational basis test see Dandridge v. Williams, 397 U.S. 471, 485 (1970). 2 For a expansion of this rationale see Van Alstyne, The Demise of the Right-Privilege Distinction in Constitutional Law, 81 Harv.

1996While it is true that a statute must withstand the strict scrutiny where a fundamental right is involved, San Antonio [Independent] School District v. Rodriguez, [ 411 U.S. 1 , 93 S.Ct. 1278 , 36 L.Ed.2d 16 (1973)]; Shapiro v. Thompson, [ 394 U.S. 618 , 89 S.Ct. 1322 , 22 L.Ed.2d 600 (1969)], this court has already held that the right to work is not fundamental and that, therefore, only the rational basis test applies.

1996While it is true that a statute must withstand the strict scrutiny where a fundamental right is involved, San Antonio [Independent] School District v. Rodriguez, [ 411 U.S. 1 , 93 S.Ct. 1278 , 36 L.Ed.2d 16 (1973)]; Shapiro v. Thompson, [ 394 U.S. 618 , 89 S.Ct. 1322 , 22 L.Ed.2d 600 (1969)], this court has already held that the right to work is not fundamental and that, therefore, only the rational basis test applies.

2024See City of Cleburne v. Cleburne Living Cntr., 473 U.S. 432, 448 (1985) (applying the rational basis test to a challenge to a city zoning ordinance).

2008In Cleburne, the Court, applying a rational-basis analysis, held unconstitutional a zoning ordinance that required a special use permit for homes for the mentally retarded inasmuch as the ordinance "appear[ed] to [the Court] to rest on an irrational prejudice against the mentally retarded." 473 U.S. at 447, 450 , 105 S.Ct. 3249 .

2003State v. Friedman, 93 Hawai'i 63, 73-74 , 996 P.2d 268, 278-79 (2000) (emphases added) (brackets and ellipsis points omitted); see also Sturch, 82 Hawai'i at 276 , 921 P.2d at 1177 (explaining that, under the rational basis test, "`[t]he test of constitutionality is whether [the] statute has a rational relation to a legitimate state interest'" (quoting Maeda v. Amemiya, 60 Haw. 662, 669 , 594 P.2d 136, 141 (1979))).

2003State v. Friedman, 93 Hawai'i 63, 73-74 , 996 P.2d 268, 278-79 (2000) (emphases added) (brackets and ellipsis points omitted); see also Sturch, 82 Hawai'i at 276 , 921 P.2d at 1177 (explaining that, under the rational basis test, "`[t]he test of constitutionality is whether [the] statute has a rational relation to a legitimate state interest'" (quoting Maeda v. Amemiya, 60 Haw. 662, 669 , 594 P.2d 136, 141 (1979))).

1999Corp. v. Castle, 79 Hawai'i 64, 86 , 898 P.2d 576, 598 (1995); see also State v. Miller, 84 Hawaii 269, 276 , 933 P.2d 606, 613 (holding that “the challenged classification must bear some rational relationship to legitimate state purposes”), reconsideration denied, 84 Hawai'i 496 , 936 P.2d 191 (1997).

1999Corp. v. Castle, 79 Hawai'i 64, 86 , 898 P.2d 576, 598 (1995); see also State v. Miller, 84 Hawaii 269, 276 , 933 P.2d 606, 613 (holding that “the challenged classification must bear some rational relationship to legitimate state purposes”), reconsideration denied, 84 Hawai'i 496 , 936 P.2d 191 (1997).

1999Corp. v. Castle, 79 Hawai'i 64, 86 , 898 P.2d 576, 598 (1995); see also State v. Miller, 84 Hawaii 269, 276 , 933 P.2d 606, 613 (holding that “the challenged classification must bear some rational relationship to legitimate state purposes”), reconsideration denied, 84 Hawai'i 496 , 936 P.2d 191 (1997).

1999Corp. v. Castle, 79 Hawai'i 64, 86 , 898 P.2d 576, 598 (1995); see also State v. Miller, 84 Hawaii 269, 276 , 933 P.2d 606, 613 (holding that “the challenged classification must bear some rational relationship to legitimate state purposes”), reconsideration denied, 84 Hawai'i 496 , 936 P.2d 191 (1997).

1998Cf. Baehr v. Lewin, 74 Haw. 530 , 852 P.2d 44 , reconsideration denied, 74 Haw. 645 , 852 P.2d 74 (1993); see also Nachtwey v. Doi, 59 Haw. 430, 437 , 583 P.2d 955, 960 (1978) (classifications based *305 upon poverty, or impacting the poor as a class, are subject to the rational basis test).

1998Cf. Baehr v. Lewin, 74 Haw. 530 , 852 P.2d 44 , reconsideration denied, 74 Haw. 645 , 852 P.2d 74 (1993); see also Nachtwey v. Doi, 59 Haw. 430, 437 , 583 P.2d 955, 960 (1978) (classifications based *305 upon poverty, or impacting the poor as a class, are subject to the rational basis test).

1993In Nakano v. Matayoshi, 68 Haw. 140 , 706 P.2d 814 (1985), this court stated that once it is determined that the statute’s purpose is legitimate, “ ‘the reform may take one step at a time, addressing itself to the phase of the problem which seems most acute to the legislative mind.’ [E]qual protection does not mean government ‘must choose between attacking every aspect of a problem or not attacking the problem at all.’ ” Id. at 153 , 706 P.2d at 822 (citations omitted).

1993In Nakano v. Matayoshi, 68 Haw. 140 , 706 P.2d 814 (1985), this court stated that once it is determined that the statute’s purpose is legitimate, “ ‘the reform may take one step at a time, addressing itself to the phase of the problem which seems most acute to the legislative mind.’ [E]qual protection does not mean government ‘must choose between attacking every aspect of a problem or not attacking the problem at all.’ ” Id. at 153 , 706 P.2d at 822 (citations omitted).

2005Baehr, 74 Haw. at 572 , 852 P.2d at 64 (“Under the rational basis test, we inquire as to whether a statute rationally furthers a legitimate state interest.

1999Cf. Baehr v. Lewin, 74 Haw. 530 , 852 P.2d 44 , reconsideration denied, 74 Haw. 645 , 852 P.2d 74 (1993). [Where] the class of persons ... who are [subject to differential treatment] is neither “suspect” nor “quasi-suspect,” we must apply the rational basis test to the case at hand.

2019Fund v. City Council , 70 Haw. 361 , 380, 773 P.2d 250 , 262 (1989) ) (emphasis omitted).

2019Fund v. City Council , 70 Haw. 361 , 380, 773 P.2d 250 , 262 (1989) ) (emphasis omitted).

2019It is well-established that "unless fundamental rights or suspect classifications are implicated, we will apply the rational basis standard of review in examining a denial of equal protection claim." KNG Corp. v. Kim , 107 Hawai'i 73 , 82, 110 P.3d 397 , 406 (2005) (quoting Sandy Beach Def.

2019It is well-established that "unless fundamental rights or suspect classifications are implicated, we will apply the rational basis standard of review in examining a denial of equal protection claim." KNG Corp. v. Kim , 107 Hawai'i 73 , 82, 110 P.3d 397 , 406 (2005) (quoting Sandy Beach Def.

1996While we have acknowledged “the liberty of [a] citizen to choose and pursue an innocent oecupation[,]” Territory v. Kraft, 33 Haw. 397, 408 (1935), “this court has already held that the right to work is not fundamental and that, therefore, only the rational basis test applies.” Nagle, 63 Haw. at 399 , 629 P.2d at 116 (citations omitted); accord, Daoang v. Department of Education, 63 Haw. 501, 504 , 630 P.2d 629, 631 (1981); Maeda v. Amemiya, 60 Haw. 662, 669 , 594 P.2d 136, 141 (1979); Ross, 846 P.2d at 1115 (“[T]he cluster of interests in state licensing of professionals is not per se viewed

1996While we have acknowledged “the liberty of [a] citizen to choose and pursue an innocent oecupation[,]” Territory v. Kraft, 33 Haw. 397, 408 (1935), “this court has already held that the right to work is not fundamental and that, therefore, only the rational basis test applies.” Nagle, 63 Haw. at 399 , 629 P.2d at 116 (citations omitted); accord, Daoang v. Department of Education, 63 Haw. 501, 504 , 630 P.2d 629, 631 (1981); Maeda v. Amemiya, 60 Haw. 662, 669 , 594 P.2d 136, 141 (1979); Ross, 846 P.2d at 1115 (“[T]he cluster of interests in state licensing of professionals is not per se viewed

1981No teacher or educational officer who has attained the age of seventy years shall be on appointment or contract. 3 In Massachusetts Board of Retirement v. Murgia, 427 U.S. 307 (1976) and Vance v. Bradley, 440 U.S. 93 (1979), the United States Supreme Court held that the rational basis standard is the applicable test where age discrimination is alleged.

1981Following its Murgia decision, the Supreme Court reiterated its support for the rational basis test in age discrimination cases in Vance v. Bradley, supra. Vance involved a challenge to the constitutionality of a congressional statute which set the retirement age for foreign service employees at 60 as opposed to civil service employees who were allowed to retire at 70.

2024See West Maui Resort Partners, 154 Hawai#i at 139-40, 547 P.3d at 472-73 (citing Gardens, 90 Hawai#i at 342, 978 P.2d at 780 ; Pac.

2024When reviewing for rational basis, "the court essentially asks whether a statute rationally furthers a legitimate state interest." Kaneohe Bay Cruises, Inc. v. Hirata, 75 Haw. 250, 260 , 861 P.2d 1, 7 (1993) (brackets omitted).

2024When reviewing for rational basis, "the court essentially asks whether a statute rationally furthers a legitimate state interest." Kaneohe Bay Cruises, Inc. v. Hirata, 75 Haw. 250, 260 , 861 P.2d 1, 7 (1993) (brackets omitted).

2020Tax Found. of Hawai#i v. State, 144 Hawai#i 175, 205, 439 P.3d 127, 157 (2019) ("It is well-established that unless fundamental rights or suspect classifications are implicated, we will apply the rational basis standard of review in examining a denial of equal protection claim." (internal quotation marks and citation omitted)).