New York Transit Authority v. Beazer

Case Date: 12/06/1978
Court: United States Court of Appeals
Docket No: none

Facts of the Case 

Carl Beazer and Jose Reyes were employees of the New York Transit Authority (NYTA). Both were heroin addicts undergoing methadone treatment. NYTA maintained a policy against hiring anyone using narcotics. Methadone was considered a narcotic, and both Beazer and Reyes were terminated after NYTA learned of their methadone use. Beazer and Reyes filed a class action against the Transit Authority, alleging that NYTA's policy discriminated against blacks and Hispanics. They cited a statistic showing that 81 percent of suspected violations of NYTA's policy were black or Hispanic. The United States District Court for the Southern District of New York ruled for Beazer, and the United States Court of Appeals for the Second Circuit affirmed this decision.

Question 

Did the New York Transit Authority's prohibition against the hiring of anybody using methadone violate Title VII of the Civil Rights Act or the Equal Protection Clause of the Fourteenth Amendment?

Argument New York Transit Authority v. Beazer - Oral ArgumentFull Transcript Text  Download MP3 Conclusion  Decision: 6 votes for New York Transit Authority, 3 vote(s) against Legal provision: Civil Rights Act of 1964, Title VII

No and no. In a 6-3 opinion, the Court reversed the Second Circuit and held that the Transit Authority's policy was not unconstitutional or illegal under the Civil Rights Act. Writing for the majority, Justice Stevens described Beazer's statistical argument as "weak", as the 81 percent statistic did not relate to methadone users specifically. The Court recognized the public safety interest in keeping narcotics users from working for NYTA. The narcotics rule was an allowable policy choice made by NYTA, and any specific exemption for methadone users from the narcotics rule would have been "costly" and "imprecise." Justice Lewis Powell wrote an opinion concurring in part and dissenting in part.