Saturday, May 17, 2014

Railway Express v. NY case brief summary

Railway Express v. NY (1949, p. 484)

 

Facts/Issue/Holding: NY traffic regulation which prohibited “advertising vehicles” but which permitted placing on a truck “business notices” relating to the business of the truck’s owner was ruled constitutional.  Deference is given to legislatures in discerning a rational relationship between classifications and the goals of the statute.

Reasoning/Major Points:
·         When not dealing with a suspect class deference given to local authorities (municipal govt., state legislature) in how they view the fulfillment of the law’s goals through the classifications they set up.  Assumes some rational relationship between these classifications and goals of statute.
o   Court defers to City’s assessment that distinctions set up by ordinance further aim of eliminating pedestrian distraction. 
o   “It is no requirement of equal protection that all evils of the same genus be eradicated or nothing at all.” 
·         Concurrence: Maintains there is no rational difference between the classifications of statute in relation to statute’s goals, but maintains that discrimination constitutional because statute distinguishes between groups who contribute to the evil out of their own self-interest (constitutional) and groups who do so “for hire” (unconstitutional).

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