Elements of the Rational Relationship Test

In Curtis v. Kline, 542 Pa. 249, 666 A.2d 265 (1995), our Supreme Court articulated the essential principles of equal protection under the United States and Pennsylvania Constitutions to be as follows: The essence of the constitutional principle of equal protection under the law is that like persons in like circumstances will be treated similarly. However, it does not require that all persons under all circumstances enjoy identical protection under the law. The right to equal protection under the law does not absolutely prohibit the Commonwealth from classifying individuals for the purpose of receiving different treatment, and does not require equal treatment of people having different needs. The prohibition against treating people differently under the law does not preclude the Commonwealth from resorting to legislative classifications, provided that those classifications are reasonable rather than arbitrary and bear a reasonable relationship to the object of the legislation. In other words, a classification must rest upon some ground of difference which justifies the classification and have a fair and substantial relationship to the object of the legislation. Id. at 254-255, 666 A.2d at 267-268. Classifications that implicate an economic interest are subject to the rational relationship test. Bixler v. Workers' Compensation Appeal Board (Walden Books), 837 A.2d 1278, 1281 (Pa. Cmwlth. 2003). The rational relationship test contains two elements: First, we determine whether the challenged statute seeks to promote any legitimate state interest or public value; and if so, we then determine whether the legislative classification is reasonably related to accomplishing that articulated state interest. Kramer v. Workers' Compensation Appeal Board (Rite Aid Corp.), 584 Pa. 309, 335, 883 A.2d 518, 534 (2005). Under this deferential standard, Courts are "free to hypothesize reasons why the legislature created the particular classification at issue...." Kramer, 584 Pa. at 336, 883 A.2d at 534.