Whitney v Heckler

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.