## Facts

- Steel Hill Development, Inc. bought approximately 510 acres in Sanbornton, New Hampshire in December 1969 to build a large residential project of roughly 500–515 homes, including a proposed “cluster” design.
- At purchase, the land was zoned “General Residence and Agricultural,” requiring a minimum lot size of 35,000 square feet; Steel Hill negotiated with the planning board during 1970 about allowing cluster development.
- While cluster discussions continued, the planning board accepted a plan for 50 conventional lots meeting existing requirements and scheduled a public hearing under local practice.
- Amid growing concern about rapid tourism-driven growth and land-use change, the Town adopted comprehensive zoning amendments that expanded conservation areas, restructured districts, and substantially increased minimum lot sizes.
- About 70% of Steel Hill’s tract was rezoned into a “forest” district with a six-acre minimum lot size, and about 30% into an agricultural district with a three-acre minimum, making Steel Hill’s high-density cluster proposal infeasible.
- The Town stated that the larger minimums were intended to control the pace of growth, preserve rural character, and manage environmental and infrastructure pressures.

## Issues

1. Whether the three- and six-acre minimum lot-size requirements, as applied to Steel Hill’s land, were so arbitrary or unreasonable that they violated substantive due process under the Fourteenth Amendment.
2. Whether the rezoning unconstitutionally singled out Steel Hill or otherwise constituted arbitrary discrimination in violation of the Equal Protection Clause.
3. Whether Steel Hill’s purchase, negotiations, and preliminary planning-board actions created a constitutionally protected expectation to develop under the prior zoning.

## Decision

- The First Circuit affirmed the district court’s judgment upholding the zoning amendments.
- The court held the large-lot requirements were rationally related to legitimate public purposes, including growth control, rural preservation, and environmental and infrastructure management.
- The court rejected the claim that Steel Hill was unconstitutionally targeted, finding the rezoning was part of broader town-wide planning and not shown to be invidious or irrational.
- The court found Steel Hill had no federal constitutional right to have zoning fixed as of purchase or preliminary negotiations absent a vested right established under applicable law.

## Legal Principles

- Zoning ordinances are presumed valid under the Fourteenth Amendment and are upheld unless “clearly arbitrary and unreasonable” with no substantial relation to public health, safety, morals, or general welfare.
- Under rational-basis review, courts do not function as “super zoning boards” and will sustain land-use classifications if supported by any plausible public-welfare justification.
- Large-lot zoning may be a permissible means to limit density, preserve rural/open-space character, and address environmental and infrastructure constraints.
- A developer’s purchase of land and preliminary planning activity generally does not create a federal constitutional entitlement to develop under existing zoning; municipalities may rezone before development rights are fixed, subject to constitutional limits.

## Conclusion

The First Circuit upheld Sanbornton’s rezoning that imposed three- and six-acre minimum lot sizes on Steel Hill’s property, concluding the measures were rationally related to legitimate municipal welfare objectives and did not constitute arbitrary, unreasonable, or discriminatory action under the Fourteenth Amendment.


Steel Hill Dev., Inc. v. Town of Sanbornton, 469 F.2d 956 (1st Cir. 1972)