United States Railroad Retirement Board v. Fritz case brief

United States Railroad Retirement Board v. Fritz case brief summary

449 U.S. 166 (1980)

CASE SYNOPSIS

Appellant United States Railroad Retirement Board challenged a decision of the United States District Court for the Southern District of Indiana which held unconstitutional a section of the Railroad Retirement Act of 1974, 45 U.S.C.S. § 231 et seq., in a class action for a declaratory judgment brought by appellee railroad employee and others.

CASE FACTS
Appellee railroad employee and others brought a class action against appellant United States Railroad Retirement Board seeking a declaratory judgment that 45 U.S.C.S. § 231b(h) was unconstitutional under the due process clause of U.S. Constitutional amendment V because it irrationally distinguished between classes of annuitants. The district court held that the differentiation was not rationally related to the congressional purposes of insuring the solvency of the railroad retirement system and protecting vested benefits, and appellant sought review.

DISCUSSION

• The court held that § 231b(h) did not violate U.S. Constitutional amendment V because Congress could have eliminated windfall benefits for all classes of employees and it was not constitutionally impermissible for Congress to have drawn lines between groups of employees for the purpose of phasing out those benefits. 
• The court held that Congress had not achieved its purpose in a patently arbitrary or irrational way, and that the current connection test was not a patently arbitrary means for determining which employees were career railroaders. 
• The judgment was reversed.

CONCLUSION

The court reversed the district court's finding that a section of the Railroad Retirement Act was unconstitutional in a class action for a declaratory judgment brought by appellee railroad employee and others against appellant United States Railroad Retirement Board, holding that the grandfather provision which expressly preserved windfall benefits for some classes of railroad employees did not violate the Fifth Amendment.