concluding 16 that “[t]he State’s rationale must be something more than the exercise of a strained 17 imagination; while the connection between means and ends need not be precise, it, 18 at the least, must have some objective basis[,]” and rejecting a proffered basis for 25 1 legislation where it had “so speculative and attenuated a connection to its goal as to 2 amount to arbitrary action”
How later courts described this case
- concluding 16 that “[t]he State’s rationale must be something more than the exercise of a strained 17 imagination; while the connection between means and ends need not be precise, it, 18 at the least, must have some objective basis[,]” and rejecting a proffered basis for 25 1 legislation where it had “so speculative and attenuated a connection to its goal as to 2 amount to arbitrary action”
- concluding that “[t]he State’s rationale must be something more than the exercise of a strained imagination; while the connection between means and ends need not be precise, it, at the least, must have some objective basis[,]” and rejecting a proffered basis for legislation where it had “so speculative and attenuated a connection to its goal as to amount to arbitrary action”
- holding that a violation of due process occurred when an administrative error caused the Illinois Fair Employment Practices Commission to hear a plaintiff's antidiscrimination claim after the expiration of a statutorily mandated limitations period, with the result that the delay finally and irrevocably extinguished the plaintiff's claim in every forum
- holding that while due process is accorded when litigation is terminated for a party’s “failure to comply with a reasonable procedural or evidentiary rule,” procedural due process still “does require, however, ... an opportunity granted at a meaningful time and in a meaningful manner for a hearing appropriate to the nature of the case.”
Written by the judges who cited it.
Distinguished
Distinguished by GEORGIA MUSLIM VOTER PROJECT v. Kemp, 918 F.3d 1262 (2019)
See *1276Logan v. Zimmerman Brush Co. , 455 U.S. 422, 435-36, 102 S.Ct. 1148, 71 L.Ed.2d 265 (1982) (explaining that Parratt is inapplicable when "it is the state system itself that destroys a complainant's property interest, by operation of law").
Distinguished by City of Philadelphia v. Perfetti, 2015 Pa. Commw. LEXIS 237 (2015)
However, Logan is inapposite to this case because the nature of the protected property interest materially differs.
Distinguished by New York State National Organization for Women v. Cuomo, 14 F. Supp. 2d 424 (1998)
Id. Therefore, the Court held, the principle enunciated in Logan was inapplicable.
Distinguished by J.W. Rickett v. Charles Jones, Warden (St. Clair) and the Attorney General of the State of Alabama, 901 F.2d 1058 (1990)
The concurrence relies on Logan v. Zimmerman Brush Co., 455 U.S. 422, 102 S.Ct. 1148, 71 L.Ed.2d 265 (1982), but Logan is inapplicable.
The opinion
*443 Justice Powell,
with whom Justice Rehnquist joins,
concurring in the judgment.
As the challenged statute now has been amended, this is a case of little importance except to the litigants. The action commenced with an isolated example of bureaucratic oversight that resulted in the denial even of a hearing on appellant’s claim of discrimination. One would have expected this sort of negligence by the State to toll the statutory period within which a hearing must be held. The Supreme Court of Illinois, however, read the statutory terms as mandatory and jurisdictional.
The issue presented, at least for me, is too simple and straightforward to justify broad pronouncements on the law of procedural due process or of equal protection. I am particularly concerned by the potential implications of the Court’s expansive due process analysis. In my view this is a case that should be decided narrowly on its unusual facts. *
The decision of the Illinois Supreme Court effectively created two classes of claimants: those whose claims were, and those whose claims were not, processed within the prescribed 120 days by the Illinois Fair Employment Practices Commission. Under this classification, claimants with identical claims, despite equal diligence in presenting them, would be treated differently, depending on whether the Commission itself neglected to convene a hearing within the prescribed time. The question is whether this unusual classification is rationally related to a state interest that would justify it.
*444 The State no doubt has an interest in the timely disposition of claims. But the challenged classification failed to promote that end — or indeed any other — in a rational way. As claimants possessed no power to convene hearings, it is unfair and irrational to punish them for the Commission’s failure to do so. The State also has asserted goals of redressing valid claims of discrimination and of protecting employers from frivolous lawsuits. Yet the challenged classification, which bore no relationship to the merits of the underlying charges, is arbitrary and irrational when measured against either purpose.
This Court has held repeatedly that state-created classifications must bear a rational relationship to legitimate governmental objectives. See, e. g., Schweiker v. Wilson, 450 U. S. 221, 230 (1981); Lindsey v. Normet, 405 U. S. 56 (1972). Although I do not join Justice Blackmun’s separate opinion, I agree that the challenged statute, as construed and applied in this case, failed to comport with this minimal standard. I am concerned by the broad sweep of the Court’s opinion, but I do join its judgment.
It is necessary for this Court to decide cases during almost every Term on due process and equal protection grounds. Our opinions in these areas often are criticized, with justice, as lacking consistency and clarity. Because these issues arise in varied settings, and opinions are written by each of nine Justices, consistency of language is an ideal unlikely to be achieved. Yet I suppose we would all agree — at least in theory — that unnecessarily broad statements of doctrine frequently do more to confuse than to clarify our jurisprudence. I have not always adhered to this counsel of restraint in my own opinion writing, and therefore imply no criticism of others. But it does seem to me that this is a case that requires a minimum of exposition.