Brief Fact Summary. A Texas city, Cleburne (Petitioner) denied a special use permit for the operation of a group home for the mentally retarded. Cleburne Living Center (Respondent) purchased a building with the intention to house thirteen mentally retarded individuals.
Synopsis of Rule of Law. The general rule is that legislation is presumed valid and will be sustained if the classification drawn by the statute is rationally related to a legitimate state interest.
Issue. Was the ordinance on its face and as applied, constitutional?
Held. No. However, the court of appeals was in error in holding that mental retardation should belong to a “quasi-suspect” classification, and that the rational basis test should apply.
The general rule is that legislation is presumed valid and will be sustained if the classification drawn by the statute is rationally related to a legitimate state interest. However, when a statute makes classifications according to race, alienage, or national origin, a heightened scrutiny applies which means that the legislation must be suitably tailored to serve a compelling state interest.
The court of appeals erred in holding that mental retardation should be afforded an intermediate level of scrutiny for constitutional purposes.
To withstand equal protection review, legislation that distinguishes between the mentally retarded and others must be rationally related to a legitimate governmental purpose.
Because the evidence did not reveal any rational basis for believing that the home would pose any special threat to the Petitioner’s legitimate interests, the court affirms the court of appeals’ decision to the extent that the ordinance is held invalid.
Dissent. The dissent argued that if the majority were really applying the rational basis test to this case, it would have been decided differently. In other words, the dissent accuses the majority of applying a heightened scrutiny and simply calling it a general scrutiny.
Discussion. It would seem that the court was trying to avoid calling the mentally retarded a suspect class on the grounds that the delineation between mentally retarded and normal would soon be blurred. The court did not want to embark on an ad hoc determination of what forms of mental retardation would fall into the suspect class and which ones would not.