In Re Hughes, by and Through Ingram
253 N.C. App. 699
| N.C. Ct. App. | 2017Background
- North Carolina enacted the Eugenics Asexualization and Sterilization Compensation Program (N.C. Gen. Stat. § 143B-426.50 et seq., 2013) to compensate victims sterilized under the State Eugenics Board between 1933–1974; $10 million was appropriated to be divided among successful claimants.
- The statute defines a “claimant” as an individual who was alive on June 30, 2013; payment to an estate is allowed only if a claimant dies after a claim vests.
- Claimants here are estates of Hughes, Redmond, and Smith — all victims who were involuntarily sterilized but died before June 30, 2013; their compensation claims were denied under § 143B-426.50(1).
- The estates appealed to the Industrial Commission, then to the Court of Appeals, contending the living-victim cutoff violated equal protection by arbitrarily excluding heirs of deceased victims.
- The N.C. Supreme Court remanded to the Court of Appeals to decide the merits of the facial equal protection challenge; the Court of Appeals (this opinion) applies rational-basis review and upholds the statute.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 143B-426.50(1)’s June 30, 2013 living-victim requirement violates equal protection | Estates: the cutoff arbitrarily denies compensation to heirs of victims who died before that date while allowing others to recover, with no legitimate state interest | State: statute rationally targets living victims to maximize meaningful compensation, limit administrative burden, and implement Task Force recommendations | Upheld — estates not similarly situated to living victims; statute bears a rational relation to legitimate government interests |
| Whether heirs/estates of deceased victims are "similarly situated" to living victims for equal protection purposes | Estates: heirs of all victims are similarly situated and disparate treatment must pass rational-basis review | State: intended beneficiaries are living victims; heirs of those who died before enactment are not similarly situated | Held — estates are not similarly situated to living victims; claim fails |
| Whether any asserted classification lacks a conceivable legitimate purpose such that rational-basis review would be failed | Estates: no valid state interest justifies the arbitrary temporal cutoff | State: legitimate interests include maximizing per-victim compensation, administrability (identifying heirs), and giving living victims restitution and emotional vindication | Held — statute survives rational-basis review; multiple rational interests identified |
| Remedy requested: facial invalidation of § 143B-426.50(1) | Estates seek relief for excluded estates and a declaration the provision is unconstitutional on its face | State defends statute’s design and legislative history (Task Force) as reasonable policy choices | Held — facial challenge rejected; remanded with instruction to deny the estates’ claims |
Key Cases Cited
- Hooper v. Bernalillo County Assessor, 472 U.S. 612 (1985) (upholding special benefits for a class when tied to legitimate compensatory/expressive governmental purposes)
- Krueger v. North Carolina Criminal Justice Education & Training Standards Commission, 230 N.C. App. 293 (2013) (summarizing equal protection principles under state and federal Constitutions)
- Wang v. UNC-CH School of Medicine, 216 N.C. App. 185 (2011) (describing similarly situated inquiry and equal protection analysis)
- Town of Beech Mountain v. County of Watauga, 91 N.C. App. 87 (1988) (explaining rational-basis review and presumption of constitutionality)