Brief Fact Summary. Households included more than two unrelated adults, in violation of a city ordinance.
Synopsis of Rule of Law. An ordinance, which assigns a number to how many unrelated people can live together is not rationally related to a government interest, and so will be invalid.
Issue. Is a zoning ordinance, which restricts those included in the definition of family reasonably related to the goal of preserving traditional family values?
We fail to see how an ordinance, which limits the number of unrelated person who may occupy a residential dwelling furthers the goal of keeping a neighborhood quiet.
Unrelated persons are artificially limited to two, whole related families may expand without limit. The ordinance indiscriminately regulates when no regulation is needed and fails to regulate where regulation is most needed.
There is no evidence that unrelated persons have any less need for the advantages of residential living. In the absence of such demonstration to justify this kind of classification, the ordinance is arbitrary and capricious under the Due Process clause of the Michigan Constitution. It limits the composition of groups in a manner that is not rationally related to the stated goals of the zoning ordinance.
Discussion. The Michigan court gives a greater protection to nontraditional families’ access to real property than does the United States Constitution.