Equal Protection Under the United States Constitution

Black v. MDMC/Benefis Healthcare [8/24/01] 2001 MTWCC 47 Statute which denies permanent partial disability benefits to injured workers who have taken social security retirement or who are eligible for full social security retirement or equivalent benefits does not violate the Equal Protection Clause of either the Montana or United States constitutions. The primary purpose of workers' compensation benefits is wage replacement and the provision is rationally related to that purpose since most people retire when eligible for social security benefits and are no longer in the labor market, thus they do not suffer a wage loss. Even though some persons may remain or wish to remain employed, the equal protection clause does not require precision in creating classifications.
Black v. MDMC/Benefis Healthcare [8/24/01] 2001 MTWCC 47"The Equal Protection Clause does not forbid classifications. It simply keeps governmental decision makers from treating differently persons who are in all relevant respects alike." The test of whether persons are in fact unalike is whether the separate classification of the persons is rationally related to a legitimate public interest.
Black v. MDMC/Benefis Healthcare [8/24/01] 2001 MTWCC 47 In determining whether a classification is related to a legitimate public interest, the Court looks not only to the legislative history of the provision but also for any "plausible reason for the classification."
Black v. MDMC/Benefis Healthcare [8/24/01] 2001 MTWCC 47 "The rationality commanded by the Equal Protection Clause does not require States to match age distinctions and the legitimate interests they serve with razorlike precision. . . . Under the Fourteenth Amendment, a State may rely on age as a proxy for other qualities, abilities, or characteristics that are relevant to the State's legitimate interests. The Constitution does not preclude reliance on such generalizations. That age proves to be an inaccurate proxy in any individual case is irrelevant . . . ." Kimel v. Board of Regents, 528 U.S. 62, 83-84 (2000).
Powell v. State Fund [12/14/00] 2000 MT 31 Where the right to receive workers' compensation benefits is not a fundamental right triggering a strict scrutiny analysis of equal protection, the test for assessing whether the statutory cap on domiciliary care benefits established in section 39-71-1107(3), MCA (1995) is the rational relationship test, which asks whether a legitimate governmental objective bears some identifiable rational relationship to a discriminatory classification.