## Facts

- Homes for the Homeless, Inc., a nonprofit corporation, planned to establish and operate a homeless shelter for approximately 715 residents in the Springfield Gardens neighborhood in Queens, New York.
- Springfield Gardens was described as a residential community of roughly 3,000 people, consisting largely of single-family homes.
- The City of New York supported the project, including by providing partial funding; the City’s Human Resources Administration was to supervise shelter operations.
- Spring-Gar Community Civic Association, Inc., a neighborhood civic association, and its chairman (suing individually and in that capacity) brought suit to stop the shelter.
- Plaintiffs sought a permanent injunction preventing the shelter from being established and operated at the proposed location.
- Plaintiffs alleged that placing a large homeless shelter in the neighborhood would threaten public health and safety, harm the community’s well-being, and diminish local property values.
- Plaintiffs asserted multiple legal theories, including claims framed as public and private nuisance, claims alleging violations of environmental review requirements, and claims alleging lack of legally required notice connected to social-services siting/operation.
- The action was decided at the trial level in the Supreme Court of the State of New York, Queens County (Civil Term), in 1987.

## Issues

1. Whether a proposed homeless shelter could be enjoined as a public or private nuisance based on predicted harms such as safety concerns and reduced property values before the facility began operating.
2. Whether alleged defects in environmental review for the shelter site warranted injunctive relief halting the project.
3. Whether alleged failures to provide required notice under social-services-related laws justified stopping the shelter’s establishment or operation.

## Decision

- The court denied plaintiffs’ request for a permanent injunction and refused to block the shelter project.
- The court rejected the nuisance-based claims as an insufficient basis to enjoin the shelter based on anticipated impacts rather than a demonstrated, legally actionable nuisance.
- The court rejected plaintiffs’ statutory challenges (including environmental and notice-based theories) as not warranting the requested equitable relief on the record presented.
- The denial of injunctive relief was later affirmed on appeal. See Homes for the Homeless, Inc., 149 A.D.2d 581, 540 N.Y.S.2d 453 (2d Dep’t 1989).

## Legal Principles

- Injunctive relief requires more than generalized neighborhood opposition or predictions of harm; courts look for a legally sufficient showing of an actual or imminent wrong.
- A nuisance claim is not established merely by speculation that a lawful facility will lead to crime, disorder, or reduced property values; the anticipated impacts must meet the legal standard for nuisance and be supported by proof.
- When a plaintiff seeks to stop a public program or facility on equitable grounds, the court weighs the claimed private harms against the public interest in providing services, including housing for people experiencing homelessness.
- Claims that a project violated environmental review requirements must show a legally material defect that supports judicial intervention; not every asserted irregularity results in an injunction.
- Alleged violations of statutory notice requirements must be tied to an enforceable duty and a remedy that fits the violation; conclusory assertions of inadequate notice do not automatically justify halting a project.

## Conclusion

In Spring-Gar Community Civic Association, Inc. v. Homes for the Homeless, Inc., a Queens County trial court refused to enjoin a City-supported plan to locate a large homeless shelter in the Springfield Gardens neighborhood, rejecting plaintiffs’ nuisance, environmental, and notice-based theories as insufficient to warrant the extraordinary remedy of a permanent injunction, and the denial of injunctive relief was later affirmed on appeal.


Spring-Gar Community Civic Association, Inc. v. Homes for the Homeless, Inc., 516 N.Y.S.2d 399, 135 Misc. 2d 689 (1987)