Cleburne and Metropolitan Life Insurance Co. v. Ward

In Cleburne and Metropolitan Life Insurance Co. v. Ward, 470 U.S. 869, 105 S.Ct. 1676, 84 L.Ed.2d 751 (1985), although the Court declined to extend strict or heightened review to classifications based on mental impairment, plaintiffs assert that the Court engaged in a stricter review than the traditional rational relationship analysis, by examining the "closeness of the fit between legislative goals and means." (Pl.Br. at 17.) Under this purportedly stricter emerging rational relationship test, plaintiffs assert the malpractice statute of limitations cannot be sustained. The city of Cleburne required a special use permit for the operation of a group home for the mentally retarded. Because they were not considered to be related to the ordinance the Court rejected the city's proffered justifications, which included the neighboring property owners' fear of the residents of the home, location of the home near a junior high school where students may be prone to harassing the mentally retarded, location of the home on a 500-year flood plain, density regulations, and lessening of traffic congestion. Since there was no rational relationship between these goals and the classification, the Court concluded that the ordinance was premised on sheer prejudice against the mentally retarded. "Requiring the permit in this case appears to us to rest on an irrational prejudice against the mentally retarded...." Cleburne, 473 U.S. at 450, 105 S.Ct. at 3259. In Metropolitan, the Court held unconstitutional an Alabama statute which required foreign insurance companies to pay a 4% tax on the premiums from policies sold in-state while insurance companies located in Alabama were required to pay a comparable tax of 1%. The legislative goals of the tax were encouragement of capital investment in Alabama and fostering the growth of the state insurance industry. The Court characterized these goals of the legislation as "the very sort of parochial discrimination that the Equal Protection Clause was intended to prevent." Metropolitan, 470 U.S. at 878, 105 S.Ct. at 1681.