Massachusetts Board Of Retirement v. Murgia

427 U.S. 307 (1976)

Facts

Murgia (P) was an officer in the Uniformed Branch of the Massachusetts State Police. The Massachusetts Board of Retirement retired him upon his 50th birthday. P sued alleging that the operation of § 26(3)(a) denied him equal protection of the laws. The District Judge dismissed P's complaint on the ground that the complaint did not allege a substantial constitutional question. On appeal, the Court of Appeals set aside the District Court judgment and remanded the case. The three-judge court filed an opinion that declared § 26(3)(a) unconstitutional on the ground that 'a classification based on age 50 alone lacks a rational basis in furthering any substantial state interest,' and enjoined enforcement of the statute. On the equal protection claim, the Court found it unnecessary to apply a strict-scrutiny test because that the age classification could not, in any event, withstand a test of rationality. The District Court held that compulsory retirement at age 50 was irrational under a scheme that assessed the capabilities of officers individually by means of comprehensive annual physical examinations.