Los Angeles Bar Association v. Eu

1992

Venue: 9th Cir.

Facts: California passes a statute that caps the number of judges for LA County. The CA Bar association challenges the constitutionality of the statute on the basis of access to justice, equal protection, and so on. All the same, it doesn't seem like LA is that bad off, when we look to statistics.

Posture: March Fong Eu is Sec. of State. District court grants summary judgment in the state's favor. Appeal.

Issue: Is the fact that cases are delayed grounds for declaring the statute unconstitutional?

Holding: No; delay is not in itslef unconstitutional, and we don't have the power to control the allocation of state resources.

Rule: There's no constitutional basis for asserting a time limit on resolution of civil casts. 14A does not require a uniform timetable to be imposed on all the states. The statute is clearly passes the "rational basis" test.

Reasoning: People have a fundamental right of access to the courts, and the ability to petition the government for redress of greivances. The right to a speedy trial, however, is not specified empirically: judging whether it is being violated requires case-by-case analysis. It's also not easy to know whether the delay in LA is the fault of the system or the litigants. But even so, it seems to be getting better rather than worse. 14A doesn't mean that all persons get treated identically, as long as there is a rational basis for the distinction. So the fact that trials in LA take longer than those in smaller towns isn't per se unconstitutional, as long as there's a rational basis for the situation. And there is: budgets are limited, and this is how the state has chosen to allocate them.

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