Familystyle of St. Paul, Inc. v. City of St. Paul

Brief Fact Summary. An organization wanted to operate a group home for the mentally ill near other group homes.

Synopsis of Rule of Law. A dispersal requirement in the operation of group homes for the mentally ill is valid under the Fair Housing Act (Act) because it is necessary to promote the mental health of the residents.

Facts. Familystyle of St. Paul, Inc. (Plaintiff) provides rehabilitative services to mentally ill persons and operates residential group homes for them. Plaintiff sought permits for additional houses. On the condition that Plaintiff would work to disperse its facilities, the city issued the temporary permits. Plaintiff failed to meet the conditions of the special use permits, and they expired. The city denied the renewal of the permits because the city requires that a new group home of the mentally ill be located at least a quarter of a mile from an existing residential program. Relying on the Act, Plaintiff challenges the actions of the city.

Issue. Is a requirement that group homes for the mentally ill be subject to spacing requirements valid under the Fair Housing Act?

Held. Yes.
The state seeks to place the mentally ill in the least restrictive environment possible and to allow them the benefits of normal residential surroundings. The licensing requirement reflects the goal of deinstitutionalization. The goal is advanced by requiring a new group home to be located at least a quarter of a mile from an existing residential program.
The spacing requirement guarantees that residential treatment facilities will be in the community, rather than in neighborhoods completely made up of group homes that re-create an institutional environment. Congress did not intend for the Act to contribute to the segregation of the mentally ill from the mainstream of our society.
The dispersal requirement as part of the licensure process is a legitimate means to achieve the state’s goals in the process of deinstitutionalization of the mentally ill.

Discussion. In upholding the spacing requirement, the court emphasizes that the requirement will help promote the mental health of the group home residents. They do not seem to be concerned with promoting integration in their decision.