## Facts

- The City of Ames adopted a comprehensive zoning ordinance regulating land use, including “residential low density” districts intended primarily for single-family dwellings.
- The ordinance defined a “single-family dwelling” as a building with one dwelling unit occupied exclusively by one “family.”
- The ordinance defined “family” to include: (1) any number of persons related by blood, marriage, or adoption; or (2) no more than three unrelated persons living together as a single, nonprofit housekeeping unit sharing common living facilities (with a separate provision allowing certain larger groups of persons with disabilities and support staff).
- Ames is home to a large university population, and the City sought to limit the movement of large student groups into single-family neighborhoods and preserve neighborhood character.
- The Ames Rental Property Association (ARPA), representing owners of houses in single-family zones, alleged the ordinance prevented leasing sufficiently large houses to more than three unrelated persons, regardless of size or actual impacts.

## Issues

1. Whether limiting occupancy in a single-family dwelling to any number of related persons but no more than three unrelated persons violates the Equal Protection Clause of the U.S. Constitution.
2. Whether the same classification violates the Equal Protection Clause of the Iowa Constitution.

## Decision

- The Iowa Supreme Court affirmed summary judgment for the City.
- The court applied rational basis review because the classification did not involve a suspect class and did not implicate a fundamental right.
- The court held the ordinance was rationally related to legitimate governmental interests, including preserving family-oriented neighborhoods and controlling density, traffic, congestion, noise, parking impacts, and transience.
- The court rejected arguments that the classification was unconstitutional because it was imperfect, overinclusive, or underinclusive.
- The court declined to invalidate the ordinance under the Iowa Constitution, finding no basis for a different result from federal equal protection analysis.

## Legal Principles

- A zoning ordinance distinguishing between related and unrelated occupants in defining “family” is reviewed under rational basis unless it burdens a suspect class or fundamental right.
- Under rational basis review, a classification is valid if it is rationally related to a legitimate governmental interest; it need not be the best or most precise means of addressing the problem.
- Legislative line-drawing in land-use regulation receives substantial deference, and over- or under-inclusiveness generally does not defeat a classification under minimal scrutiny.
- Equal protection under the Iowa Constitution may be interpreted independently, but absent a persuasive reason to depart, similar rational-basis analysis may apply and yield the same outcome.

## Conclusion

The Iowa Supreme Court held that Ames’s definition of “family,” allowing any number of related persons but limiting unrelated occupants of a single-family dwelling to three, survives rational-basis review and does not violate equal protection under either the U.S. or Iowa Constitution.


Ames Rental Prop. Ass'n v. City of Ames, 736 N.W.2d 255 (Iowa 2007)