What is the limitation on the scope of an individual's right to sue for damages under the Fourteenth Amendment?

The second limitation mentioned in Lawton v. Steele, supra, has been stated in a number of ways. The means employed must have a real and substantial relation to,⁵ and must have some fair tendency to accomplish or aid in the accomplishment of⁶ the ends sought. On the other hand, if the means chosen are arbitrary and unreasonable,⁷ capricious,⁸ or beyond the necessities of the case,⁹ then the Fourteenth Amendment is violated, and it is the duty of the federal courts to declare the statute, ordinance, order or regulation void.¹⁰

[98 F.2d 633]