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Village of Belle Terre v. Boraas

Supreme Court of the United States · 1974 · Property
416 U.S. 1 (1974)
Updated
PropertyZoningLand useEqual Protectionfamily ordinancesingle-family dwellingunrelated personspolice power

Facts

Belle Terre, a small Long Island village, limited land use to one-family dwellings and defined "family" as persons related by blood, adoption, or marriage living and cooking together, or no more than two unrelated persons living and cooking together as a single housekeeping unit. The Dickmans owned a house in the village and leased it to student occupants; ultimately six students lived there, none related to the others by blood, adoption, or marriage. After the village served an order to remedy violations of the ordinance, the owners and some tenants sued under 42 U.S.C. § 1983. They claimed the ordinance was unconstitutional because it barred their occupancy arrangement.

Issue

May a village, consistent with the Constitution, enforce a zoning ordinance limiting occupancy of a one-family dwelling to related persons or no more than two unrelated persons? More specifically, does such a land-use classification violate constitutional protections by burdening travel, migration, association, privacy, or equal protection?

Rule

When reviewing economic and social land-use legislation, courts apply deferential rational basis review: the law is valid if it is reasonable, not arbitrary, and bears a rational relationship to a permissible state objective. Legislative line-drawing in zoning need not be perfect, and if the validity of the classification is fairly debatable, legislative judgment controls.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.
The city of Fairfield, Ohio, zones a neighborhood for one-family dwellings only. Its code defines a family as any number of related persons living together, or no more than two unrelated persons living together as a single housekeeping unit; four unrelated pharmacy interns rent a house there and challenge the rule under equal protection.

What is the strongest argument that the ordinance is constitutional?

Explanation. The majority treated this kind of occupancy restriction as ordinary social and economic zoning legislation, not as a burden on a fundamental right. Therefore deferential rational basis review applies. The ordinance is upheld if it is reasonable, not arbitrary, and bears a rational relationship to permissible land-use goals such as preserving a quiet neighborhood and reducing density-related problems like traffic, parking, and noise.