City of Ladue v. Horn

Missouri Court of Appeals · Property

PropertyZoningSingle-family residential useConstitutional challenges to land-use regulationzoningfamily definitionsingle-family residencerational basis

Facts

Ladue's zoning ordinance designated certain districts as one-family residential and defined a family as one or more persons related by blood, marriage, or adoption occupying a dwelling as an individual housekeeping organization. Defendants, an unmarried man and woman, purchased and occupied a seven-bedroom house in such a district along with their children; they shared a bedroom, maintained a joint checking account for household expenses, ate and entertained together, and disciplined each other's children. Ladue demanded that they vacate because they were not a family under the ordinance, and when they refused the city sought injunctive relief. Defendants argued that their household functioned as the equivalent of a family and that the ordinance violated constitutional rights of association, privacy, and equal protection.

Issue

Whether a municipal zoning ordinance limiting occupancy in a single-family residential district to persons related by blood, marriage, or adoption is unconstitutional as applied to an unmarried couple and their children who live together as a household. The court also considered whether the ordinance was arbitrary under federal or Missouri constitutional principles.

Rule

A zoning ordinance is presumed valid, and courts defer to the legislative judgment unless the municipality acted arbitrarily. When a zoning classification based on biological or legal relationship among household members does not involve a fundamental right or suspect classification, it is constitutional if it is reasonable, not arbitrary, and rationally related to a permissible objective such as promoting the public health, safety, morals, or general welfare.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In suburban Columbus, a municipal ordinance limits occupancy in a single-family district to "one or more persons related by blood, marriage, or adoption, living together as a single housekeeping unit." Maya Patel and Jordan Reed, an unmarried couple, live there with Maya's teenage son and Jordan's daughter, sharing expenses, meals, and childcare.

If Maya and Jordan argue that the ordinance infringes their rights of privacy and intimate association and therefore must satisfy strict scrutiny, how should a court most likely rule under the majority opinion's approach?

Explanation. The majority treated this kind of ordinance as land-use regulation, not as a direct burden on a fundamental right. Because the classification turns on biological or legal relationships and does not involve a suspect class or fundamental interest, rational-basis review applies. Under that standard, the ordinance is valid if reasonably related to a permissible objective; the city need not use the least restrictive means. (Derived from City of Ladue v. Horn (n.d.).)