## Facts

- A corporation sought to lease and operate a group home for 13 adults with intellectual disabilities in a residential neighborhood in Cleburne, Texas.
- Under the city’s zoning scheme, various multi-person residential uses were allowed in the relevant district, but “hospitals for the insane or feebleminded” required a special use permit.
- City officials classified the proposed group home as falling within the special-permit category.
- After a public hearing at which neighbors objected, the city council denied the special use permit.
- The operator and others sued, alleging the ordinance and the denial violated the Equal Protection Clause.
- The district court upheld the ordinance and its application.
- The court of appeals reversed, treating intellectual disability as a quasi-suspect classification requiring heightened scrutiny and finding the ordinance invalid on its face and as applied.

## Issues

1. Whether intellectual disability is a quasi-suspect classification requiring heightened scrutiny under the Equal Protection Clause.
2. Whether, under the proper standard of review, the city’s denial of a special use permit for the group home violated equal protection (facially and/or as applied).

## Decision

- The Supreme Court held that intellectual disability is not a quasi-suspect classification and does not trigger heightened scrutiny.
- The Court applied rational-basis review to the zoning classification and the permit denial.
- The Court declined to invalidate the ordinance on its face.
- The Court held the permit denial unconstitutional as applied because the asserted justifications were not rationally connected to legitimate governmental interests in light of comparable uses allowed as of right.
- The Court concluded the denial rested on irrational prejudice and impermissible community bias rather than valid zoning concerns.
- The judgment was affirmed in part and reversed in part: heightened-scrutiny analysis was rejected, but the as-applied equal protection violation was sustained.

## Legal Principles

- Social and economic regulations generally receive rational-basis review and will be upheld if rationally related to a legitimate governmental interest.
- Intellectual disability is not a suspect or quasi-suspect class for equal protection purposes; classifications affecting this group ordinarily receive rational-basis review.
- Even under rational-basis review, government action fails if it is explained only by irrational prejudice or animus rather than legitimate objectives.
- “Negative attitudes,” “vague fears,” or community hostility toward a disadvantaged group are not legitimate grounds for differential zoning treatment.
- In assessing rationality, courts may compare the challenged treatment to similarly situated uses permitted under the same zoning rules to test whether the stated reasons actually account for the distinction.

## Conclusion

The Court refused to elevate classifications involving intellectual disability to heightened scrutiny but held that Cleburne’s denial of a special use permit for a group home violated equal protection because it lacked a rational basis and reflected impermissible prejudice rather than legitimate zoning concerns.


City of Cleburne v. Cleburne Living Ctr., Inc., 473 U.S. 432 (1985)