Altagracia Sanchez v. Office of the State Superintendent of Education, No. 21-7014 (D.C. Cir. 2022)Annotate this Case
The District of Columbia’s Office of the State Superintendent of Education (OSSE) regulates childcare facilities, including by setting minimum qualifications for their workers. OSSE issued a rule requiring many childcare workers to obtain an associate’s degree or its equivalent in a field related to early childhood education. Two childcare workers and a parent filed a lawsuit to challenge the new college requirements. They allege violations of their substantive due process and equal protection rights, as well as of the nondelegation doctrine.
On remand, the district court dismissed, this time on the merits. In rejecting Plaintiffs’ substantive due process and equal protection claims, the court concluded that the college requirements are rational, including in the distinctions they draw between different classes of daycare workers. And in rejecting Plaintiffs’ nondelegation doctrine claim, the court held that the statute granting regulatory authority to OSSE bears an intelligible principle to guide the agency’s work.
The DC Circuit affirmed. The court explained that under rational-basis review, the policy choices of the political branches are “not subject to courtroom fact-finding and may be based on rational speculation unsupported by evidence or empirical data. And here, as Plaintiffs acknowledge in their complaint, OSSE issued its regulations in part based on a report from the National Academies recommending a bachelor’s degree requirement for all educators of children ages zero to eight. Thus, the court found that a conceivably rational justification for the college requirements is readily apparent, and, in this context, that is all due process requires.