Village of Belle Terre v. Borass

Brief Fact Summary. Belle Terre is a village on Long Island, New York, which is home to 220 homes and 700 people. The Village restricted land use to single family dwellings. The Appellees are lessors and lessees of a house in the village where six college students lived, none of them related.

Synopsis of Rule of Law. A law does not violate the Equal Protection Clause of the Fourteenth Amendment if the law is “reasonable and not arbitrary”, and bears “a rational relationship to a permissible state objective.”

Facts. Belle Terre is a village on Long Island, New York, which is home to 220 homes and 700 people. The Village restricted land use to single family dwellings. “Family” is defined under the zoning ordinance as one or more people related by blood, adoption or marriage living as a single housekeeping unit, or not more than two persons living together as a unit not related by blood, adoption or marriage. The Appellees are lessors and lessees of a house in the village where six college students lived, none of them related. The Village served Appellees with an “Order to Remedy Violations” of the ordinance. The Appellees filed suit under 42 U.S.C. Section: 1983 for an injunction and a declaration that the ordinance was unconstitutional. The federal district court held the ordinance was constitutional. The court of appeals reversed and held that the ordinance was unconstitutional. The Village appealed.

Issue. Is the ordinance constitutional?

Held. Yes. Reversed.
The Court first rejects the Appellees’ contentions that the ordinance is unconstitutional because of interference with travel, interference with migration within a state, that social homogeneity is not a legitimate state interest, that the ordinance intrudes on the right of privacy, that it should not matter whether residents are married, and that the ordinance is against the open traditions of American society.
The Court deals with economic and social legislation where legislatures have historically drawn lines which the Court respects against the charge of a violation of the Equal Protection Clause of the Fourteenth Amendment if the law is “reasonable and not arbitrary”, and bears “a rational relationship to a permissible state objective.”
The Court found that the ordinance’s definition of a “family” as not more than two unmarried people is a proper function of the legislature not the judiciary.
The fact that the ordinance provides for unmarried couples to live together and be called a family means that the ordinance is not discriminatory against unmarried couples.
The police power is not confined to the elimination of filth, stench, and unhealthy places. It is proper to lay out zones where family values, youth values and the blessings of quiet living is preserved.

Dissent. The dissent would hold that the ordinance burdens the students’ (lessees) fundamental rights of association and privacy guaranteed by the First and Fourteenth Amendments.

Discussion. This Court gave great deference to the legislative function in this case. This would appear to be a fairly broad enlargement of the police power. Consider the impact of the ordinance on non-traditional families.