Facts
- A township zoning ordinance for an R-3 residential district defined a permitted “family” in a single-family dwelling as: one person, or persons related by blood, marriage, or adoption, plus no more than one unrelated person (excluding servants).
- Two married couples owned single-family homes in the district and lived with their children and six unrelated single adults in each household.
- All residents were members of a nonprofit religious organization and lived together as a single housekeeping unit, intending permanent residence.
- The township issued zoning violation notices more than a year after move-in because each home housed more than one unrelated person.
- The households did not violate building-code space or occupancy standards; the homes could have accommodated additional people under those neutral limits.
- The residents challenged enforcement, asserting constitutional protections including privacy, association, and religious exercise; the dispute proceeded to the state’s highest court after denial of a variance.
Issues
- Whether a zoning ordinance that caps the number of unrelated persons who may live in a single-family dwelling is a reasonable, nonarbitrary exercise of police power under the Due Process Clause of the Michigan Constitution.
- Whether limiting occupancy based on kinship status, rather than neutral density-related measures, bears a real and substantial relation to legitimate zoning objectives such as controlling congestion, noise, and neighborhood character.
Decision
- The Michigan Supreme Court held the ordinance unconstitutional under the Due Process Clause of the Michigan Constitution as applied to prohibit the defendants’ households.
- The court concluded the unrelated-person numerical cap was unreasonable and arbitrary because it lacked a rational connection to the township’s stated objectives.
- The court invalidated enforcement of the restrictive “family” definition against the defendants.
Legal Principles
- Under Michigan constitutional due process, zoning classifications must bear a real and substantial (rational) relation to legitimate governmental interests and may not be arbitrary.
- A numerical limitation on unrelated co-occupants in a dwelling is invalid when it functions as a kinship-based proxy for density or neighborhood impacts without evidence that unrelated households uniquely cause the targeted harms.
- A rule that permits unlimited growth of related households while sharply limiting unrelated residents may fail due process where the purported concerns (e.g., noise, traffic, overcrowding) can arise irrespective of legal relationship.
- When governmental interests are density and external effects, neutral regulations (e.g., occupancy, floor-area, parking) are more directly related than relationship-based caps.
Conclusion
The court struck down the township’s single-family occupancy restriction because its cap on unrelated residents operated as an arbitrary kinship classification, not a rational method of advancing legitimate zoning goals, and therefore violated Michigan’s due process guarantee.