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
- Whether intellectual disability is a quasi-suspect classification requiring heightened scrutiny under the Equal Protection Clause.
- 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.