## Facts

- North Dakota’s Workmen’s Compensation Act provided mandatory coverage for employees in “hazardous employment” but excluded “agricultural service” from mandatory coverage.
- Elvin Benson worked as a general farm laborer performing typical farm tasks (e.g., livestock care, machinery operation, and maintenance).
- Benson was injured while performing his farm duties.
- The North Dakota Workmen’s Compensation Bureau denied benefits, classifying Benson’s employment as excluded agricultural service.
- Benson challenged the denial, arguing the agricultural exclusion violated equal protection under the U.S. and North Dakota Constitutions.
- A district court twice ruled the exclusion unconstitutional; after an earlier remand, the case returned to the North Dakota Supreme Court for a merits decision.

## Issues

1. Whether excluding “agricultural service” from mandatory workers’ compensation coverage violates equal protection under the Fourteenth Amendment.
2. Whether the same exclusion violates equal protection under the North Dakota Constitution.
3. Whether the agricultural/nonagricultural coverage distinction has a rational relationship to a legitimate governmental purpose.

## Decision

- The North Dakota Supreme Court reversed the district court.
- The Court held the agricultural exclusion constitutional under both federal and state equal protection guarantees.
- The Court applied rational-basis review because the statute involved an economic/social welfare classification, not a suspect class or fundamental right.
- The Court concluded conceivable legitimate reasons supported the legislature’s choice to exclude agricultural service (including economic burdens on small farming operations and administrative/risk-allocation differences).
- The Bureau’s denial of mandatory benefits to Benson, based on the exclusion, was sustained.

## Legal Principles

- Economic and social welfare classifications are reviewed under rational-basis scrutiny unless they involve a suspect class or a fundamental right.
- Under rational-basis review, a classification is upheld if it is reasonably related to a legitimate governmental purpose, including when a rational basis can be conceived.
- Statutes are presumed constitutional, and the challenger bears the burden to show the classification is arbitrary or lacks a rational connection to legitimate objectives.
- Courts generally do not reweigh the wisdom or fairness of legislative policy choices when any plausible rational basis supports the classification.

## Conclusion

The court upheld North Dakota’s statutory exclusion of agricultural service from mandatory workers’ compensation coverage, holding that the legislature could rationally treat farm workers differently from other covered employees without violating equal protection.


Benson v. N.D. Workmen’s Comp. Bureau, 283 N.W.2d 96 (N.D. 1979)