## Facts

- Compton Heights, a historic St. Louis neighborhood, was subject to an 1893 restrictive covenant limiting each lot to a building used exclusively as a “private residence” and forbidding “trade or business.”
- Missouri purchased a home in the neighborhood to operate a small group home for six developmentally disabled adult males with two resident supervisors.
- Neighboring property owners and a neighborhood association opposed the plan and sued in state court to enforce the covenant and prevent operation of the home.
- After plaintiffs’ attempt to intervene in the state action was denied, the residents filed a federal suit seeking declaratory and injunctive relief under the Fair Housing Act (as amended in 1988) and 42 U.S.C. § 1983.
- Trial evidence showed the residents were screened for suitability; the home operated as a stable “functional family” with minimal turnover; and expert testimony indicated the home would not reduce nearby property values.
- The private defendants characterized the home as a “rooming house” or “business” and asserted the covenant was being applied neutrally based on prior enforcement against commercial uses.

## Issues

1. Whether enforcing the restrictive covenant to exclude the group home violates the Fair Housing Act’s prohibition on disability discrimination, including the duty to make reasonable accommodations.  
2. Whether private property owners and a neighborhood association act “under color of state law” for purposes of § 1983 by suing in state court to enforce the restrictive covenant.

## Decision

- The court found the residents were persons with disabilities protected by the Fair Housing Act.
- The court held that applying the covenant to bar the group home would make housing unavailable to the residents because of disability-related needs and would deny them an equal opportunity to use and enjoy a dwelling.
- The court concluded that allowing the group home to operate was a reasonable accommodation that would not fundamentally alter the residential character of the neighborhood and was not shown to harm property values.
- The court entered declaratory and injunctive relief under the Fair Housing Act, enjoining enforcement of the covenant to preclude operation of the group home.
- The court rejected the § 1983 claim against the private defendants, holding their covenant-enforcement litigation did not constitute state action.

## Legal Principles

- A group home for developmentally disabled adults can qualify as a residential “dwelling” use where it functions like a stable household rather than a transient or commercial operation.
- A facially neutral restrictive covenant may violate the Fair Housing Act when its application, in context, effectively excludes persons with disabilities from a residential setting and a reasonable accommodation would prevent that exclusion.
- A reasonable accommodation may include modifying how a covenant or similar rule is applied when necessary to afford persons with disabilities an equal opportunity to live in and enjoy a home, so long as the change does not fundamentally alter the residential nature of the area.
- Private parties ordinarily do not become state actors under § 1983 merely by invoking state judicial processes to enforce private restrictive covenants, absent significant state involvement or joint action.

## Conclusion

The court permanently barred enforcement of the neighborhood’s restrictive covenant to shut down a small, supervised group home for developmentally disabled adults because the Fair Housing Act required a reasonable accommodation, but it declined to impose § 1983 liability on the private challengers for lack of state action.


Martin v. Constance, 843 F. Supp. 1321 (E.D. Mo. 1994)