The Third Circuit engaged in a more rigorous rational basis review in Medora v. Colautti, 602 F.2d 1149. See also Ranschburg v. Toan, 709 F.2d 1207 (8th Cir. 1983). In Medora, the Third Circuit said "[t]he importance of receiving welfare is not the sole reason we feel that close scrutiny of rationality is justified in this case."
Neither classification is unlawful simply because it is not a perfect test for need. Plaintiffs rely heavily on Ranschburg v. Toan, 709 F.2d 1207 (1983), in which the Eighth Circuit ruled that Missouri's definition of "disabled" for purposes of the state's "Utilicare" program violated the equal protection clause. The purpose of the Utilicare program was to help financially needy elderly and disabled citizens pay their utility bills.
In the area of economics and social welfare, equal protection analysis requires that the state establish at the challenged classification is rationally related to some legitimate governmental purpose. Ranschburg, 709 F.2d 1207, 1209 (8th Cir. 1983) (citing United States Dep't of Agric. v. Moreno, 413 U.S. 528, 533 (1973) ; Dandridge v. Williams, 397 U.S. 471, 485 (1970); Medora v. Colautti, 602 F.2d 1149, 1152 (3d Cir. 1979); Alcala v. Burns, 545 F.2d 1101, 1104 (8th Cir. 1976)). 49. A virtually identical social welfare classification in Missouri failed to withstand Equal Protection scrutiny in Ranschburg, 709 F.2d 1207 (8th Cir. 1983).
Respondents assert that the only difference between incapacitated SSI-ineligible spouses and those who qualify for GA-U is the source of their income and that it is irrational to deny benefits based solely on income source. They refer to a recent case, Ranschburg v. Toan, 709 F.2d 1207 (8th Cir. 1983) which, they contend, held that income source is an impermissible basis for distinguishing among the needy disabled. Ranschburg involved a Missouri statute which provided "Utilicare" assistance in paying heating bills to persons with a certain level of income who were considered "disabled".
To hold otherwise would "render the rational basis test a nullity and would ‘suspend the operation of the Equal Protection Clause in the field of social welfare law’ " as it relates to all U.S. residents who dwell in Puerto Rico. Baker v. City of Concord, 916 F.2d 744, 749 (1st Cir. 1990) (quoting Ranschburg v. Toan, 709 F.2d 1207, 1211 (8th Cir. 1983) ). We decline to read these cases so broadly.
In the cases the braiders cite, the government did not have a legitimate interest. See Craigmiles v. Giles , 312 F.3d 220, 224 (6th Cir. 2002) (restricting casket sales to funeral directors—"protecting a discrete interest group from economic competition"—"is not a legitimate governmental purpose"); St. Joseph Abbey v. Castille , 712 F.3d 215, 222 (5th Cir. 2013) (same); Ranschburg v. Toan , 709 F.2d 1207, 1211 (8th Cir. 1983) (finding "intent to discriminate is not a legitimate state interest"); Fowler v. United States , 633 F.2d 1258, 1263 (8th Cir. 1980) ("no rational interest" "to summarily discharge without cause a mentally retarded worker, but not a non-retarded worker who performs the same job").The braiders argue that the State's means do not fit its purposes.
See Powers, 379 F.3d at 1226 (Tymkovich, J., concurring) (“The end result of the majority's reasoning is an almost per se rule upholding intrastate protectionist legislation.”); cf. Ranschburg v. Toan, 709 F.2d 1207, 1211 (8th Cir.1983) (“Although states may have great discretion in the area of social welfare, they do not have unbridled discretion. They must still explain why they chose to favor one group of recipients over another.
Id. at 1154-55. Similarly, in Ranschburg v. Toan, 709 F.2d 1207 (8th Cir. 1983), the Eighth Circuit struck down a Missouri regulation which limited the class of needy, disabled persons eligible to get financial assistance for heating costs to those who received certain other benefits. The State's argument that the challenged classification was rationally based because it allocated the limited funding available to the neediest individuals was rejected on the ground that some of the proxy programs were not based on need.
They must still explain why they chose to favor one group of recipients over another." Ranschburg v. Toan, 709 F.2d 1207, 1211 (8th Cir. 1983). Upon consideration of the evidence produced at trial, the Court is persuaded that the District's system for allocating emergency family shelter satisfies the Equal Protection Clause. All families, except those with obvious eligibility problems, are placed on a waiting list for shelter. Their waiting list numbers are called in order, given family size and other appropriate considerations.
When a statutory classification serves no legitimate government purpose other than to discriminate, it denies equal protection of the laws. See Ranschburg v. Toan, 709 F.2d 1207, 1211 (8th Cir. 1983) (rejecting argument that challenged classification is rationally based because statute accomplishes stated goal of treating one class differently from another since such a classification is, in effect merely a restatement of the classification); Cleburne, 473 U.S. at 450, 105 S.Ct. at 3259; Silbowitz v. Secretary of Health, Education Welfare, 397 F. Supp. 862 (S.D.Fla. 1975), aff'd, 430 U.S. 924, 97 S.Ct. 1539, 51 L.Ed.2d 768 (1977); Burstyn v. Miami Beach, 663 F. Supp. 528, 536-37 (S.D.Fla. 1987). Notwithstanding the deference generally accorded legislative enactments, the Government may not rely on budgetary considerations to justify classifications not otherwise rationally related to a legitimate government purpose.