Facts
- A Long Island village adopted a zoning ordinance limiting land use in certain areas to “one-family dwellings.”
- The ordinance defined “family” as persons related by blood, adoption, or marriage living as one household, and allowed no more than two unrelated persons to live together as a household.
- The ordinance excluded uses such as boarding, lodging, fraternity, and multiple-dwelling houses.
- A homeowner leased a house to a tenant who lived there with five other university students; all six occupants were unrelated.
- The village cited the property for violating the ordinance’s occupancy limitation.
- The owners and tenants sued, alleging violations of equal protection and asserted rights of association, travel, and privacy.
- The district court upheld the ordinance; the court of appeals reversed on equal protection grounds; the Supreme Court reversed the court of appeals and upheld the ordinance.
- Before Supreme Court review concluded, the student tenants moved out.
Issues
- Whether a zoning ordinance limiting “one-family” occupancy to related persons (or no more than two unrelated persons) violates the Fourteenth Amendment by denying equal protection or infringing asserted rights of association, travel, or privacy.
- Whether the dispute became moot after the tenant plaintiffs vacated the house.
Decision
- The Court held the case was not moot because the ordinance continued to affect the property’s value.
- The Court upheld the ordinance, concluding it did not burden a fundamental right and did not draw a suspect classification.
- Applying rational basis review, the Court found the ordinance reasonable and rationally related to permissible governmental objectives associated with single-family residential zoning.
- The Court rejected claims that the ordinance unconstitutionally restricted association or privacy, reasoning that it did not bar other forms of association and regulated occupancy for land-use purposes.
- Justice Brennan dissented on mootness, arguing no live controversy remained after the tenants moved.
- Justice Marshall dissented on the merits, arguing the ordinance impermissibly restricted household choice and associational freedom and warranted more searching review.
Legal Principles
- Land-use regulations that do not burden a recognized fundamental right and do not employ a suspect classification are reviewed under rational basis scrutiny.
- A municipality may define “family” for single-family zoning to favor related household units, and the Constitution permits such social and economic line-drawing if not arbitrary or capricious.
- Preserving a quiet residential character, limiting density-related effects (such as traffic, parking, and noise), and favoring traditional family-oriented neighborhoods are legitimate governmental objectives for zoning.
- A case challenging an ordinance is not moot where the ordinance continues to impose concrete effects on property interests, such as diminishing property value.
Conclusion
The Court sustained a municipality’s single-family zoning definition that limited unrelated cohabitants, holding the ordinance was a rational land-use measure that neither implicated suspect classifications nor infringed a fundamental constitutional right, and further held the dispute remained justiciable despite the tenants’ departure because the ordinance continued to affect the property.