## Facts

- Robert and Joan McMinn owned a four-bedroom single-family house in a “D Residence” zoning district in the Town of Oyster Bay.
- In 1976, they leased the house to four unrelated men (ages 22–25).
- The zoning ordinance defined “single-family” occupancy as: (1) any number of persons related by blood, marriage, or adoption, or (2) two unrelated persons if both were at least 62 years old.
- Single-family houses were permitted as of right; rooming and boarding houses required Town Board approval after a public hearing.
- The Town brought a criminal action against the McMinns on the theory that occupancy by four unrelated individuals constituted more than one “family” under the ordinance.
- The Town asserted objectives including preserving traditional neighborhood character, limiting density, and reducing traffic, parking congestion, and noise.

## Issues

1. Whether the ordinance’s “family” definition, which generally excluded unrelated persons from occupying single-family homes, facially violated substantive due process under the New York Constitution.
2. Whether the Town could, consistent with state due process, condition single-family occupancy on biological or legal relationship rather than on household functioning (e.g., a single housekeeping unit).

## Decision

- The Court of Appeals affirmed the Appellate Division.
- The court held the ordinance was facially unconstitutional under the New York Constitution’s due process clause insofar as it barred occupancy of single-family homes by persons unrelated by blood, marriage, or adoption.
- The court left undisturbed the validity of limiting single-family occupancy to a “single housekeeping unit” and recognized the Town’s ability to regulate true rooming or boarding houses through appropriate zoning mechanisms.

## Legal Principles

- A zoning restriction must bear a rational relationship to legitimate governmental objectives to satisfy substantive due process under the New York Constitution.
- Municipal zoning power is broad but may not be exercised in an arbitrary, capricious, or unreasonable manner.
- Impacts commonly associated with residential uses (traffic, noise, congestion) correlate more directly with the number and conduct of occupants than with their familial status; a blood-or-marriage-based definition may therefore be irrational if it is both overinclusive and underinclusive.
- A municipality may regulate single-family residential use by requiring occupancy as a single housekeeping unit, but it may not categorically exclude functionally family-like households based solely on the absence of formal relationships.

## Conclusion

The court invalidated the Town’s restrictive “family” definition as lacking a rational connection to the stated zoning objectives under state due process, while permitting regulation aimed at ensuring single-housekeeping-unit occupancy and controlling rooming or boarding house uses.


McMinn v. Town of Oyster Bay, 66 N.Y.2d 544 (N.Y. 1985)