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Revere v. Canulette5/15/1998
classification and the standard of review is heightened, requiring the proponent to establish that the classification substantially furthers an important governmental objective.
At the other end of the spectrum are laws that do not classify individuals on any of the enumerated bases. These laws are subject to the minimal standard of scrutiny for every statutory classification Ä that is, the classification must be rationally related to a legitimate governmental purpose. Whenever a person disadvantaged by a legislative classification not enumerated in Section 3 seeks to have the classification declared unconstitutional, that person has the stringent burden of demonstrating that the classification does not suitably further any appropriate governmental interest.
Moore v. RLCC Technologies, Inc., 668 So.2d at 1140-41.
The Court also discussed the inquiry necessary to properly analyze an equal protection case, as follows:
In order to analyze an equal protection challenge, it is helpful to make three basic inquiries. The first inquiry involves identifying the challenged classification. The classification means the distinction made between one group and another or the basis on which one group is treated differently from another. . . . The second inquiry involves identifying the person who suffers the discrimination. . . . The third inquiry involves determining the Legislature's purpose for the classification. On this issue, the placement of the burden of proof is critical. As discussed above, the placement of the burden of proof and the determination of the appropriate level of scrutiny depends on where the challenged classification falls in the spectrum for analyzing equal protection challenges under La. Const. art. I, § 3.
Moore v. RLCC Technologies, Inc., 668 So.2d at 1141-42.
Plaintiff claims that heightened scrutiny should be used in this case because prisoners fall under the classification of "physical condition" under Article I, Section 3 of the Louisiana Constitution. We disagree. "Physical condition" refers to classifications on the basis of one's health or handicap. See, e.g., Sibley v. Board of Supervisors of Louisiana State University, 477 So.2d 1094 (La. 1985) (on rehearing); Cook v. New Orleans Police Department, 94-2490 (La. App. 4th Cir. 7/26/95), 659 So.2d 530.
Because none of the enumerated classes are involved, the classification created by La.R.S. 44:31.1 is subject to the minimal standard of scrutiny Ä that is, the classification must be rationally related to a legitimate governmental purpose. Armstead v. Phelps, 449 So.2d 1049, 1053 (La. App. 1st Cir. 1984). The law is presumed constitutional, and plaintiff has the burden of proving that the classification does not suitably further any appropriate governmental interest.
Applying the rational relationship standard to this case, we find a rational basis exists for the classification under La. R.S. 44:31.1 of inmates who have exhausted their appellate remedies and have not demonstrated that the public records request is for the purpose of filing for post-conviction relief. The legislature could have reasonably determined that the numerous requests by inmates for copies of matters in the public records have a detrimental effect on the effective and efficient upkeep of the public records, particularly when these requests are for unnecessary documents. In its endeavor to assure the custodian's efficiency and effectiveness, the statute does not limit an inmate's access to those records necessary for meaningful access to the courts in connection with the appeals process. Therefore, we conclude that the statute is rationally related to the legitimate state
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