City of Cleburne v. Cleburne Living Center

Citation. 473 U.S. 432, 105 S.Ct. 3249, 87 L.Ed2d 313 (1985).

Brief Fact Summary.

Plaintiff was denied a special use permit for the operation of a group home for the mentally challenged and brought suit under the Equal Protection Clause.

Synopsis of Rule of Law.

The mentally challenged to do not belong to a quasi-suspect class. As such, legislation that distinguishes on the basis of mental handicaps must be rationally related to a legitimate government purpose.

Facts.

Plaintiff was denied a special use permit for the operation of a group home because it violated a local zoning ordinance. Plaintiff brought suit, challenging the validity of the ordinance, arguing that it discriminated against individuals on the basis of their mental handicaps.

Issue.

Whether the mentally challenged belong to a quasi-suspect class requiring heightened scrutiny.

Held.

No. The mentally challenged belong to a quasi-suspect class requiring heightened scrutiny.

Concurrence.

Justice Stevens

Every law that puts the mentally challenged in a special class is not presumptively irrational. That being said, the record convinces me that this permit was required because of irrational fears of neighboring property owners, rather than for the protection of mentally challenged individuals who would reside in Plaintiff’s home.

Justice Marshall

This Court is downplaying the lengthy history of purposeful unequal treatment of the mentally challenged. While I agree the ordinance should struck down, it must be done so under a more rigorous standard.

Discussion.

While the lower court applied the incorrect level of scrutiny, the Texas law still fails. This is because the zoning ordinance is not rationally related to a government interest. The record does not reveal any rational basis for believing that the home would pose any special threats. All that is shown are vague, undifferentiated negative attitudes showing irrational prejudice.