## Facts

- Edmonds, Washington enforced a zoning code for single-family residential zones defining “family” as (1) any number of related persons or (2) up to five unrelated persons.
- Oxford House operated a group home in a single-family zone for 10–12 unrelated adults recovering from alcoholism and drug addiction.
- The parties stipulated the residents were “handicapped” under the Fair Housing Act (FHA).
- The City issued criminal citations to the owner and a resident for violating the family-definition rule.
- The City sought a federal declaratory judgment that its family-definition provision was exempt from the FHA under 42 U.S.C. § 3607(b)(1) as a “maximum number of occupants” restriction.
- Oxford House counterclaimed, alleging the City failed to make a reasonable accommodation under 42 U.S.C. § 3604(f)(3)(B); the United States intervened and filed a consolidated FHA action.
- The district court ruled for the City, treating the ordinance as exempt under § 3607(b)(1).
- The Ninth Circuit reversed, holding the exemption did not cover the ordinance.
- The Supreme Court granted review limited to whether the ordinance qualified for the § 3607(b)(1) exemption.

## Issues

1. Whether a zoning provision defining “family” to permit unlimited related persons but no more than five unrelated persons is a “restriction[] regarding the maximum number of occupants permitted to occupy a dwelling” exempt from the FHA under 42 U.S.C. § 3607(b)(1).

## Decision

- The Supreme Court affirmed the Ninth Circuit in a 6–3 decision (Justice Ginsburg).
- Edmonds’ family-definition provision was not a “maximum number of occupants” restriction within § 3607(b)(1) and therefore was not categorically exempt from FHA scrutiny.
- The Court did not decide whether Edmonds violated the FHA or whether a reasonable accommodation was required; it remanded for further proceedings under the correct interpretation of § 3607(b)(1).

## Legal Principles

- The FHA’s § 3607(b)(1) exemption is limited to reasonable, across-the-board numerical occupancy ceilings aimed at preventing overcrowding and protecting health and safety.
- A rule that regulates household composition by defining who may live together (e.g., distinguishing related from unrelated persons) is not a “maximum occupancy” restriction merely because it sets a numerical limit on one category (unrelated persons) while allowing unlimited related persons.
- Family-composition zoning provisions are not automatically outside the FHA; they remain subject to FHA review, including claims alleging failure to make reasonable accommodations for persons with disabilities.

## Conclusion

The Court held that Edmonds’ single-family “family” definition is a land-use household-composition rule, not a total occupancy cap, so it falls outside the FHA’s maximum-occupancy exemption and remains subject to FHA standards, with the merits of any requested reasonable accommodation left for further proceedings.


City of Edmonds v. Oxford House, Inc., 514 U.S. 725 (1995)