Whitney v Heckler

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In Whitney v. Heckler, a group of physicians challenged the constitutionality of the Deficit Reduction Act, which imposed a temporary freeze on the fees that non-participating physicians could charge Medicare patients. The Eleventh Circuit held that this freeze did not violate substantive due process based on its findings that:

  • it bore a reasonable relation to a valid legislative purpose
  • it was neither arbitrary nor discriminatory
  • it was not a bill of attainder because it did not inflict punishment on the plaintiff physicians.