## Facts

- The New York City Transit Authority (NYCTA) operated subway and bus systems and employed about 47,000 workers, many in safety-sensitive jobs.
- NYCTA maintained a longstanding policy barring employment of persons who used “narcotic drugs,” which NYCTA applied to all current participants in methadone maintenance programs.
- A certified class consisted of present or prospective NYCTA employees denied employment or discharged solely because of participation in methadone maintenance.
- Named plaintiffs included two former employees discharged after NYCTA discovered their methadone use and two applicants denied employment for the same reason.
- Plaintiffs alleged the blanket exclusion violated (1) the Equal Protection Clause and (2) Title VII based on disparate impact on Black and Hispanic individuals.
- The district court found many methadone users were employable and that NYCTA could screen out unsuitable candidates through ordinary personnel procedures; it enjoined NYCTA from excluding individuals solely due to methadone participation (with limited safety-position and program-duration conditions) and later also found a Title VII violation.
- The Second Circuit affirmed on equal protection grounds without reaching Title VII.
- The Supreme Court granted review and held the case was not moot despite intervening federal legislation potentially bearing on disability-related discrimination because claims arose earlier and monetary relief remained at issue.

## Issues

1. Whether NYCTA’s blanket exclusion of all current methadone users from all employment violates the Equal Protection Clause.
2. Whether the exclusion violates Title VII based on disparate impact and lack of business justification on the record presented.

## Decision

- The Supreme Court reversed the judgment below and upheld NYCTA’s blanket exclusion.
- Under equal protection, the Court applied rational-basis review because the rule was an employment/safety policy not aimed at a suspect class or a fundamental right.
- The Court held the policy was rationally related to legitimate objectives of safety and efficiency, even if overinclusive and excluding some employable methadone users.
- The Court rejected the view that equal protection required NYCTA to adopt individualized screening as a less restrictive alternative.
- On Title VII, the Court found plaintiffs’ statistical showing insufficiently tied to methadone use specifically and concluded the policy was related to NYCTA’s business needs on this record.

## Legal Principles

- Under rational-basis review, a government employer’s classification may be overinclusive and still satisfy equal protection if it is reasonably related to legitimate objectives and is not arbitrary or invidious.
- Equal protection does not require the least restrictive means or individualized assessments for general personnel and safety regulations reviewed under rational-basis scrutiny.
- In disparate-impact litigation, plaintiffs must present statistical proof that adequately isolates the challenged practice’s effect; weak or non-specific statistics may fail to establish a Title VII violation.
- A facially neutral employment rule tied to safety and operational reliability may qualify as job-related and consistent with business needs on the evidentiary record presented.

## Conclusion

The Court upheld NYCTA’s categorical exclusion of current methadone users, holding that safety- and efficiency-based bright-line personnel rules can survive rational-basis equal protection review despite imperfect fit, and that Title VII disparate-impact liability was not established where the statistical proof did not sufficiently connect the exclusion to a demonstrated discriminatory impact and the employer’s safety rationale was supported on the record.


N.Y.C. Transit Auth. v. Beazer, 440 U.S. 568 (1979)