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The approach under which the Supreme Court now reviews
congressional legislation is “a relatively relaxed
standard reflecting the Court’s awareness that the
drawing of lines that create distinctions is peculiarly
a legislative task and an unavoidable one”. Schweiker
v. Wilson, 450 U.S. 221, 234 (1981) (reviewing SSI
program under equal protection component of Fifth
Amendment). Legislative classifications will be upheld
so long as they bear a “rational relation to a
legitimate legislative goal”, Weinberger v. Salfi, 422
U.S. 749, 772 (1975); “advances legitimate legislative
goals in a rational fashion”, Schweiker v. Wilson, 450
U.S. at 234; have “some ‘reasonable basis’”, Dandridge
v. Williams, 397 U.S. 471, 485 (1970), quoting Lindsley
v. Natural Carbonic Gas Co., 220 U.S. 61, 78 (1911);
“have support in considerations of policy and practical
convenience”, Steward Machine Co. v. Davis, 301 U.S.
548, 584 (1937); do not achieve their purposes in a
patently “arbitrary or irrational way”, U.S. Railroad
Retirement Bd. v. Fritz, 449 U.S. 166, 177 (1980); Duke
Power Co. v. Carolina Env. Study Group, 438 U.S. 59, 83
(1978); and do not “manifest a patently arbitrary
classification utterly lacking in rational
justification”, Flemming v. Nestor, 363 U.S. 603, 611
(1960).
See also Reno v. Flores, 507 U.S. 292, 303 (1993) (rejecting a
substantive due process challenge to a regulation that was
“rationally connected to a governmental interest * * * and
* * * not * * * excessive in relation to that valid purpose”);
Leikind v. Schweiker, 671 F.2d 823, 825 (4th Cir. 1982) (“The
standard of review under substantive due process is that the
statute must be upheld if there is any rational basis for the
classification made therein.”) (citing Usery v. Turner Elkhorn
Mining Co., 428 U.S. 1 (1976)).
Section 2035(c) bears a rational relation to the legitimate
legislative goal of eliminating incentives to make “deathbed
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