City of Cleburne v. Cleburne Living Center, Inc.
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City of Cleburne v. Cleburne Living Center, Inc., 473 U.S. 432 (1985), was a U.S. Supreme Court case involving discrimination against the mentally retarded.
In 1980, Cleburne Living Center, Inc (CLC) submitted a permit application seeking approval to build a group home for the mentally retarded. The city of Cleburne, Texas refused to grant CLC a permit on the basis of a municipal zoning ordinance. CLC then sued the City of Cleburne on the theory that the denial of the permit violated the Equal Protection rights of CLC and their potential residents.
Applying rational basis review the U.S. Supreme Court struck down the ordinance as applied to CLC. The Court declined to rule that the mentally retarded were a quasi-suspect or suspect class.
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[edit] Facts of the Case
In July of 1980, Jan Hannah purchased a building at 201 Featherston [sic] Street in the city of Cleburne with the intent of leasing it to CLC so that they could operate it as a group home for the mentally retarded. The home was intended to house a total of 13 mentally disabled men and women. CLC staff would supervise the residents at all times. The house itself had 4 bedrooms and 2 baths, with another half bath to be added.
The city of Cleburne informed CLC that a special use permit would be required for a group home such as this, and so CLC submitted the permit application. The city's zoning regulations required that a special use permit, renewable annually, was required for the construction of "[hospitals] for the insane or feeble-minded, or alcoholic [sic] or drug addicts, or penal or correctional institutions." (436) The city had classified the group home as a "hospital for the feebly minded". (437).
The city of Cleburne held a public hearing on the meeting, after which they denied the special use permit to CLC on a vote of 3 to 1.
[edit] Case History
After their special use permit was denied CLC filed suit in Federal District Court against the city alleging that the zoning ordinance was invalid on its face and as applied because it discriminated against the mentally retarded in violation of the equal protection rights of CLC and its potential residents. The Federal District Court found that if the potential residents of CLC's group home had not been mentally retarded the permit would have been granted. However, they upheld the city's ordinance and actions as constitutional. The District Court held that the mentally retarded were neither a suspect nor a quasi-suspect class and therefore the rational basis test should be applied. The court held that the ordinance was rationally related to the city's legitimate interest in "the legal responsibility of CLC and its residents, . . . the safety and fears of residents in the adjoining neighborhood," and the number of people to be housed in the home.
The Federal Court of Appeals for the Fifth Circuit reversed the decision of the District Court. The Court of Appeals held that mental retardation was a quasi-suspect class and therefore intermediate scrutiny should be applied to the ordinance. Applying the heightened scrutiny standard to the ordinance, the court held it was unconstitutional on its face and as applied.
The U.S. Supreme Court granted certiorari.
[edit] The U.S. Supreme Court Opinion
Justice Byron White, writing the opinion of the court, invalidated the ordinance as applied to CLC. The Court held that the denial of the permit was based on irrational prejudice against the mentally retarded and hence was invalid under the Equal Protection Clause of the Fourteenth Amendment.
However, in its holding, the Court also ruled that mental retardation was not a quasi-suspect or suspect class. Therefore, any legislation that distinguishes between the mentally retarded and others must be rationally related to a legitimate government interest in order to withstand equal protection review. This is also known as rational basis review and is the lowest level of review given under the Equal Protection Clause. The Court went on to state that the mentally retarded are a "large and diversified group" and specific state and federal legislation aimed at helping those who are mentally disabled would also come under attack if a heightened standard of scrutiny was applied.
Justice Thurgood Marshall, dissenting in part and concurring in the result of invalidating the statute, argued that due to the history of discrimination against the mentally retarded, the Court should employ a higher standard of scrutiny (see Equal Protection scrutiny) when examining laws that regulated those with mental disabilities.
[edit] Significance of the Case
Although the U.S. Supreme Court declined to classify the mentally retarded as a suspect or quasi-suspect class, the Cleburne decision represents one of the few instances in which the Supreme Court has held government legislation to be unconstitutional when applying a rational basis level of review.
