Thursday, November 14, 2013

New York City Transit Authority v. Beazer case brief

New York City Transit Authority v. Beazer case brief summary
440 U.S. 568 (1979)

Respondent potential employees filed an action against petitioner public employer based on its policy of refusing to employ persons who use methadone. The district court held that the policy was unconstitutional, and the United States Court of Appeals for the Second Circuit affirmed. The employer's petition for writ of certiorari was granted.

This litigation was brought by four individuals as a class action on behalf of all persons who had been or would in the future be subject to discharge or rejection as employees of the public employer, a transit authority, by reason of participation in a methadone maintenance program. Their complaint alleged that the employer's blanket exclusion of all former her*in addicts receiving methadone treatment was illegal under Title VII of the Civil Rights Act of 1964 (Title VII), 42 U.S.C.S. § 2000e et seq., and the Equal Protection Clause of the Fourteenth Amendment.


  • The court held that as the rule was not motivated by racial animus, there was no rebuttal claim that it was merely a pretext for intentional discrimination, and the findings did not support the conclusion that the regulation prohibiting the use of narcotics violated Title VII. 
  • While it may have been unwise for the employer to rely on a general rule instead of individualized consideration of every job applicant, it concerned matters of personnel policy that did not violate equal protection principles, and the Constitution did not authorize a federal court to interfere in such policy decisions.

The court reversed the judgment.

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