Wednesday, November 6, 2013

Massachusetts Board of Retirement v. Murgia case brief

Massachusetts Board of Retirement v. Murgia case brief summary
427 U.S. 307 (1976)

Appellee police officer commenced an action against appellant retirement board, challenging Mass. Gen. Laws Ann. ch. 32, § 26(3)(a) (1966), which required his retirement as a uniformed state police officer at the age of 50. A three-judge court of the United States District Court for the District of Massachusetts entered a judgment in favor of the police officer. The retirement board sought review of that decision by certiorari.

The retirement board appealed the trial court's decision in favor of the police officer. He had challenged the validity of § 26(3)(a), which mandated his retirement at the age of 50, on equal protection grounds.


  • On appeal, the Court held that the appropriate level of equal protection review was rationality and that the statute furthered a legitimate governmental interest. 
  • The Court stated that the strict scrutiny standard of review was applicable to equal protection claims only when the classification impermissibly interfered with the exercise of a fundamental right or operated to the peculiar disadvantage of a suspect class. 
  • Because governmental employment was not a per se right, a lower standard of review was appropriate for legislation that restricted employment opportunities. 
  • Moreover, those over 50 failed to constitute a suspect class as they had not been subjected to the history of purposeful discrimination usually associated with racial and ethnic minorities. 
  • Thus, as § 26(3)(a)furthered the State's interest in ensuring the physical preparedness of its uniformed police officers, there was a rational basis for its requirement of mandatory retirement at the age of 50.

The Court reversed the trial court's judgment.

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