## Facts

- Massachusetts law required a uniformed Massachusetts State Police officer to be retired upon reaching age 50.
- Robert D. Murgia, a uniformed officer, was mandatorily retired on his 50th birthday under the statute.
- About four months before retirement, Murgia passed a physical examination finding him fit to perform his duties.
- The evidentiary record described uniformed state police work as physically demanding and requiring versatility, with limited opportunities for less strenuous assignments.
- Murgia challenged the mandatory retirement rule as a denial of equal protection.

## Issues

1. Whether mandatory retirement at age 50 for uniformed state police officers violates the Equal Protection Clause of the Fourteenth Amendment.
2. Whether age is a suspect classification or continued governmental employment is a fundamental right requiring strict scrutiny.
3. If rational basis review applies, whether the age-50 cutoff is rationally related to a legitimate state interest.

## Decision

- The Supreme Court reversed the three-judge district court in a per curiam decision and upheld the statute.
- The Court held that strict scrutiny was inapplicable because the statute neither burdened a fundamental right nor disadvantaged a suspect class.
- Applying rational basis review, the Court held the mandatory retirement rule was rationally related to the legitimate objective of ensuring the physical readiness of the uniformed police force.
- The Court accepted that the age line could be imperfect (over- or under-inclusive) without violating equal protection.

## Legal Principles

- Strict scrutiny applies only when a classification interferes with a fundamental right or targets a suspect class.
- Continued governmental employment is not a fundamental right for equal protection purposes.
- Age-based classifications are not suspect and generally receive rational basis review.
- Under rational basis review, a law is constitutional if it is rationally related to a legitimate governmental objective; imperfect legislative line-drawing does not alone establish an equal protection violation.
- A state may use age as a proxy for declining physical capacity in a demanding public-safety occupation when the proxy has a rational connection to fitness for duty.

## Conclusion

The Court held that Massachusetts could require uniformed state police officers to retire at age 50 because age is not a suspect classification, public employment is not a fundamental right, and the age cutoff rationally furthered the state’s interest in maintaining a physically prepared police force.


Massachusetts Bd. of Ret. v. Murgia, 427 U.S. 307 (1976)