Law School Case Brief
Belle Terre v. Boraas - 416 U.S. 1, 94 S. Ct. 1536 (1974)
A quiet place where yards are wide, people few, and motor vehicles restricted are legitimate guidelines in a land-use project addressed to family needs. This goal is a permissible one. The police power is not confined to elimination of filth, stench, and unhealthy places. It is ample to lay out zones where family values, youth values, and the blessings of quiet seclusion and clean air make the area a sanctuary for people.
An action was instituted in the United States District Court for the Eastern District of New York, challenging the constitutionality of a zoning ordinance of defendant Village of Belle Terre, New York, restricting land use to one-family dwellings. The word "family" meant one or more related persons or a number of persons but not exceeding two that were not related. The ordinance permitted occupancy by any number of persons related by blood, adoption, or marriage. Plaintiff homeowners were served by the Village with an order to remedy violations of the ordinance arising from the owners' leasing of the home to plaintiff tenants, who were unrelated college students. Plaintiffs filed suit under 42 U.S.C.S. § 1983 contending that the ordinance violated equal protection rights and rights of association, travel, and privacy. The district court upheld the constitutionality of the ordinance. On appeal, however, the United States Court of Appeals for the Second Circuit reversed.
Was the ordinance valid?
The Supreme Court of the United States reversed the appellate court's judgment and found that the Village's ordinance that restricted land use to one-family dwellings was constitutional. The Court reasoned that the ordinance was not aimed at transients, it involved no procedural disparity inflicted on some but not on others, and it involved no fundamental right guaranteed by the United States Constitution. The Court found that a quiet place where yards were wide, people few, and motor vehicles restricted were legitimate guidelines in a land-use project addressed to family needs. The legislature properly exercised its discretion in defining "family" to include no more than two unrelated persons.
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