Ames Rental Property Association v. City of Ames

Brief Fact Summary.

Ames Rental Property Association brought suit against the City of Ames seeking a declaratory judgment, regarding whether the City of Ames’ zoning ordinance was constitutional.

Synopsis of Rule of Law.

A zoning ordinance may exclude more than three unrelated individuals from the definition of the term “family” without violating the Equal Protection Clause of the United States Constitution or the Iowa Constitution.

Facts.

Iowa State University was located in the City of Ames, Defendant. Defendant passed a law to prevent a large number of college students from moving into residential areas in which families resided in. Defendant’s characterized the term “family” to exclude groups of three unrelated individuals. Plaintiff, Ames Rental Property Association, a corporation housing real-property owns in Ames, filed suit and sought a declaratory judgment on the definition of the term family. Further, Plaintiff sought to determine whether the zoning ordinance constituted a violation of the United States Constitution and Iowa Constitution’s Equal Protection Clause. Defendant’s filed a motion for summary judgment the declaratory action, and the district court granted the motion. Subsequently, Plaintiff’s appealed the district court’s order.

Issue.

Whether a zoning ordinance that excludes more groups larger than three unrelated individuals form the definition of the term “family” is a violation of the United States Constitution or the Iowa Constitution.

Held.

No, a zoning ordinance that excludes more groups larger than three unrelated individuals form the definition of the term “family” is not a violation of the United States Constitution or the Iowa Constitution.

Dissent.

The ordinance is a violation of the Equal Protection Clause, under the Iowa Constitution because it is both over-inclusive and under-inclusive. The ordinances forbids a household to contain four, quiet, single individuals, while permitting a loud family. Additionally, the ordinance is based on historical social norms, which are outdated, causing a disadvantage to the poor and the elderly.

Discussion.

In Village of Belle Terre v. Boraas, 416 U.S. 1 (1974), the United States Supreme Court upheld a stricter ordinance, compared to the one in this case, on the grounds that it did not violate the Equal Protection Clause under the United States Constitution. Although the United State’s Constitution’s interpretation by the Court is not binding on the interpretation of the Iowa Constitution, it is certainly persuasive. Here, because there is not a protected class or fundamental right at issue, the court must use the rational basis test to determine whether the ordinance is rationally related to the governments legitimate interest. The court finds that the government has a legitimate interest in the preservation of familial neighborhoods.  Further, this interest justifies the governments implementation of the ordinance’s purpose, to keep the neighborhoods zoned for single-family dwellings, free from large groups of college students living together. Moreover, although the ordinance is based on imprecise stereotypes, it is rationally related to the legitimate governmental interest. Therefore, the district court’s ruling should be affirmed.