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Constitutional Law Keyed to Choper
New York City Transit Authority v. Beazer
Citation:
440 U.S. 568 (1979)Facts
The New York City Transit Authority (TA) operates New York City’s subway system and certain bus lines, employing approximately 47,000 people. TA enforces a general policy against employing persons who use narcotic drugs, including methadone, which is used in treatment programs for heroin addiction. About 40,000 persons in New York City receive methadone maintenance treatment, with about 63% of those in public programs being black or Hispanic. The evidence showed that while methadone is effective for treating heroin addiction, a significant percentage (20-30%) of those in maintenance programs for over a year still engage in illicit drug or alcohol use. The respondents, who were either dismissed from employment or denied employment by TA because of their participation in methadone maintenance programs, filed a class action alleging that TA’s blanket exclusion violated the Equal Protection Clause and Title VII. The District Court found that substantial numbers of methadone users are just as employable as members of the general population and that normal screening procedures could identify qualified applicants. The court enjoined TA from denying employment solely based on methadone use but allowed exclusion from safety-sensitive positions and required at least one year of successful participation in a program.
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