## Facts

- The City of Hanford maintained a downtown commercial area known for a concentration of furniture retailers.
- Hanford created a Planned Commercial (PC) zoning district near a shopping mall and generally did not allow furniture stores or furniture sales in that district.
- Adrian and Tracy Hernandez leased a roughly 4,000-square-foot store in the PC district to sell mattresses, bedroom furniture, and related accessories.
- When the Hernandezes sought occupancy approval, the City advised that furniture sales were not permitted in the PC zone; an occupancy certificate allowed certain home-furnishings accessories but excluded furniture.
- The PC district included large department stores that had been selling furniture, prompting complaints about inconsistent enforcement.
- After a public study session with affected stakeholders, the City amended its ordinance to continue the general prohibition but permit “large department stores” (at least 50,000 square feet) to sell furniture only within a single area not exceeding 2,500 square feet.
- The Hernandezes nonetheless sold furniture, were cited for zoning violations, and sued challenging the ordinance.

## Issues

1. Whether the zoning ordinance was invalid as an improper attempt to regulate economic competition rather than to serve a legitimate public purpose within municipal police power.
2. Whether allowing limited furniture sales by large department stores while prohibiting all furniture sales by smaller PC-district retailers violated equal protection under rational-basis review.

## Decision

- The California Supreme Court reversed the Court of Appeal and reinstated judgment for the City.
- The Court held the ordinance was a valid exercise of municipal police power even though it affected competition.
- The Court held the large-department-store exception did not violate equal protection because the classification was rationally related to legitimate governmental objectives, including supporting the downtown district and retaining regional retail anchors in the PC zone.

## Legal Principles

- Municipal land-use regulation may pursue economic and commercial welfare objectives as part of the police power if reasonably related to legitimate public purposes.
- Under rational-basis review, an economic or zoning classification is upheld if any reasonably conceivable facts could supply a rational basis; line-drawing need not be exact.
- Equal protection does not require that similarly regulated entities be treated identically when a municipality can rationally distinguish between them (including by store type and overall size) to further legitimate zoning goals.
- A generally applicable zoning exception defined by objective criteria is less likely to be treated as arbitrary or invidious than a measure aimed at particular parties.

## Conclusion

The court upheld Hanford’s furniture-sales restrictions and its limited exception for large department stores, concluding the ordinance furthered legitimate municipal objectives and survived deferential rational-basis equal protection review.


Hernandez v. City of Hanford, 41 Cal. 4th 279 (2007)