Ohio Bureau of Employment Svcs. v. Hodory, 431 U.S. 471 (1977)

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Author: U.S. Supreme Court

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Ohio Bureau of Employment Svcs. v. Hodory, 431 U.S. 471 (1977)

Ohio Bureau of Employment Services v. Hodory


No. 75-1707


Argued February 28, 1977
Decided May 31, 1977
431 U.S. 471

APPEAL FROM THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OHIO

Syllabus

Appellee, an employee of United States Steel Corporation (USS) at a plant in Ohio, was furloughed when the plant was shut down because of a reduction in fuel supply resulting from a nationwide strike of workers at USS’s coal mines. Appellee applied to appellant Ohio Bureau of Employment Services for unemployment benefits, but his claim was disallowed under an Ohio statute that disqualified a worker from such benefits if his unemployment was "due to a labor dispute other than a lockout at any factory . . . owned or operated by the employer by which he is or was last employed." While appellee’s request for reconsideration was pending before the Board of Review, he filed a class action in Federal District Court against appellants, the Bureau and its director, for declaratory and injunctive relief, asserting that the Ohio statute conflicted with certain provisions of the Social Security Act (SSA) and that, as applied, it was irrational and had no valid public purpose, in violation of the Due Process and Equal Protection Clauses of the Fourteenth Amendment. Concluding that abstention was not proper, the District Court held that the statute, as applied to appellee and the class members, violated those Clauses.

Held:

1. Abstention is not required under either Younger v. Harris, 401 U.S. 37, or Railroad Comm’n v. Pullman Co., 312 U.S. 496. Pp. 477-481.

(a) Where Ohio has concluded to submit the constitutional issue to this Court for immediate resolution, Younger principles of equity and comity do not require this Court to refuse Ohio the immediate adjudication it seeks. Pp. 477-480.

(b) Nor is Pullman abstention appropriate where the possible benefits of abstention have become too speculative to justify or require avoidance of the constitutional question. Pp. 480-481.

2. The Ohio statute is neither in conflict with, nor is it preempted by 42 U.S.C. § 503(a) (the provision of the SSA that precludes the Secretary of Labor from certifying payment of federal funds to state unemployment compensation programs unless state law provides for such methods of administration as the Secretary finds are "reasonably calculated to insure full payment of unemployment compensation when due"), or the Federal Unemployment Tax Act (FUTA). Pp. 482-489.

3. The Ohio statute, which has a rational relation to a legitimate state interest, is constitutional. Pp. 489-493.

(a) The statute does not involve any discernible fundamental interest or affect with particularity any protected class, and the test of constitutionality, therefore, is whether the statute has a rational relation to a legitimate state interest. P. 489.

(b) In considering the constitutionality of the statute, this Court must view its consequences not only for the recipient of the benefits, but also for the contributors to the compensation fund, and, although the system may provide only "rough justice" and a rough form of state "neutrality" in labor disputes, the statute cannot be said to be irrational, and the need for limitation of the liability of the compensation fund is a legitimate state interest. Pp. 489-493.

408 F.Supp. 1016, reversed.

BLACKMUN, J., delivered the opinion of the Court, in which all Members joined except REHNQUIST, J., who took no part in the consideration or decision of the case.

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Chicago: U.S. Supreme Court, "Syllabus," Ohio Bureau of Employment Svcs. v. Hodory, 431 U.S. 471 (1977) in 431 U.S. 471 431 U.S. 472. Original Sources, accessed May 19, 2024, http://www.originalsources.com/Document.aspx?DocID=Y9JDWQY9VVGSTM2.

MLA: U.S. Supreme Court. "Syllabus." Ohio Bureau of Employment Svcs. v. Hodory, 431 U.S. 471 (1977), in 431 U.S. 471, page 431 U.S. 472. Original Sources. 19 May. 2024. http://www.originalsources.com/Document.aspx?DocID=Y9JDWQY9VVGSTM2.

Harvard: U.S. Supreme Court, 'Syllabus' in Ohio Bureau of Employment Svcs. v. Hodory, 431 U.S. 471 (1977). cited in 1977, 431 U.S. 471, pp.431 U.S. 472. Original Sources, retrieved 19 May 2024, from http://www.originalsources.com/Document.aspx?DocID=Y9JDWQY9VVGSTM2.