N.Y.C. Transit Auth. v. Beazer


Methadone, a drug used to treat heroin addiction, was disallowed from being in the systems of any employees of the NYC Transit Authority as a condition of employment.  Two employees were fired as a result of the new rule and two others who applied for jobs with the Authority were not hired as a result.  Plaintiffs argued at trial that methadone was a recovery drug for heroin users and therefore should be made a condition of employment.  Moreover, the drug is unlikely to result in addiction and has the stated benefit of relieving addiction.  Lower courts adopted the Plaintiff’s arguments and ruled in their favor.


Whether a government agency can classify particular people in terms of their past or present drug use as a basis of employment.


Yes, decision reversed.  The court addressed more closely whether the government policy was sufficiently narrowly tailored so as to avoid discriminating against particular subclasses.  The court held that the particular law is narrowly tailored because so many people typically drop out of substance abuse programs, even when they use methadone as a treatment mechanism.  The law postpones eligibility until the drug patient has undergone recovery, which is rational.

More importantly, the court wrote that this is a personnel decision made within the context of a government agency adopting certain hiring practices.  This is not a state law of agency created “rule.”  Personnel decisions are policies which government agencies can more freely make without being subjected to the strict scrutiny the court places on regulations that either textually discriminate or discriminate in their eventual impact.

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