New York City Transit Authority v. Beazer Case Brief

Why is the case important?

A New York City Transit Authority rule barred the employment of persons who use narcotics. The Transit Authority applied the rule to all persons taking methadone – a drug widely used in the treatment of heroine addiction.

Facts of the case

Carl Beazer and Jose Reyes were employees of the New York Transit Authority (NYTA). Both were heroin addicts undergoing methadone treatment. NYTA maintained a policy against hiring anyone using narcotics. Methadone was considered a narcotic, and both Beazer and Reyes were terminated after NYTA learned of their methadone use. Beazer and Reyes filed a class action against the Transit Authority, alleging that NYTA’s policy discriminated against blacks and Hispanics. They cited a statistic showing that 81 percent of suspected violations of NYTA’s policy were black or Hispanic. The United States District Court for the Southern District of New York ruled for Beazer, and the United States Court of Appeals for the Second Circuit affirmed this decision.

Question

Where a substantial number of methadone users were capable of performing jobs at the Transit Authority, does the Constitution permit the Transit Authority to make a blanket exclusion of all users from all jobs at the Transit Authority?

Answer

Yes. The Court of Appeals, affirming the District Court, is reversed.
Justice John Paul Stevens stated that the assumptions upon which the Transit Authority’s rule are based concern matters of personnel policy that do not implicate the concerns the Equal Protection Clause of the Constitution are intended to protect. The Transit Authority’s rule serves the general objectives of safety and efficiency. The rule is not directed against any class of persons characterized by some unpopular trait. Therefore, it does not create the likelihood of bias on the part of the ruling majority.

Conclusion

No.

  • Case Brief: 1979
  • Petitioner: New York City Transit Authority
  • Respondent: Carl Beazer et al.
  • Decided by: Burger Court

Citation: 440 US 568 (1979)
Argued: Dec 6, 1978
Decided: Mar 21, 1979