## Facts

- Bessie Layne leased property in Pittsburgh located in an R-4 Residential zoning district and sought to operate it as a boarding house.
- The Pittsburgh zoning ordinance permitted rooming houses in R-4 districts but did not permit boarding houses.
- The ordinance defined a boarding house as a building (other than a hotel) with not more than one dwelling unit where meals and lodging are provided to persons not residing in the dwelling unit.
- Rooming houses were treated as a different use category, providing lodging to nonresidents but not meals.
- The Zoning Board of Adjustment denied Layne’s requested use because boarding houses were not a permitted use in the R-4 district.
- The Court of Common Pleas affirmed the Board; the Commonwealth Court reversed on equal protection grounds; the Pennsylvania Supreme Court reviewed on the City’s appeal.

## Issues

1. Whether a zoning ordinance violates equal protection by permitting rooming houses but excluding boarding houses from the same residential district.
2. Whether the distinction between boarding houses (meals and lodging) and rooming houses (lodging only) lacks a rational relationship to public health, safety, morals, or general welfare.

## Decision

- The Pennsylvania Supreme Court reversed the Commonwealth Court and upheld the ordinance.
- The Court held that excluding boarding houses from R-4 districts while allowing rooming houses does not violate equal protection.
- The Court concluded that the classification had a rational basis and that the challenger did not overcome the presumption of constitutionality.
- The Board’s denial of permission to operate a boarding house in the R-4 district was reinstated.

## Legal Principles

- Zoning classifications are primarily for the legislative body; courts will not interfere unless it is obvious the classification lacks a substantial relationship to public health, safety, morals, or general welfare.
- A zoning ordinance is presumed valid; the challenger bears the burden to prove it is clearly unconstitutional.
- Under rational-basis review, differential treatment of land uses does not violate equal protection if any legitimate public purpose reasonably supports the classification.
- A municipality may treat uses differently where operational characteristics (such as providing meals implicating health regulation) support a rational distinction.

## Conclusion

The court sustained Pittsburgh’s decision to treat boarding houses differently from rooming houses in an R-4 residential district, holding that the meals-and-lodging feature of boarding houses provided a rational basis for exclusion and that the challenger failed to prove an equal protection violation.


Layne v. Zoning Bd. of Adjustment of the City of Pittsburgh, 501 Pa. 224, 460 A.2d 1088 (Pa. 1983)