The Equal Protection Clause of the Fourteenth Amendment commands that no state shall deny to any person within its jurisdiction the equal protection of the laws, which is essentially a direction that all persons similarly situated should be treated alike. U.S. Const. amend. XIV, § 5 empowers congress to enforce this mandate, but absent controlling congressional direction, the courts have themselves devised standards for determining the validity of state legislation or other official action that is challenged as denying equal protection.
Respondent sought to open a home for the mentally retarded in petitioner city. Under the zoning ordinance, petitioner refused to give respondent the permit. The zoning ordinance specifically restricted the home because the occupants were mentally retarded even though the home complied with space requirements for the occupants. Respondent alleged that the ordinance was unconstitutional and in violation of the Equal Protection Clause.
Did the Texas ordinance violate the Equal Protection Clause?
The Court held that the mentally retarded were not a quasi-suspect class. The Court held that to withstand equal protection review, legislation that distinguished between the mentally retarded and others must be rationally related to a legitimate governmental purpose. As no rational purpose was present, the Court held that the ordinance was invalid and remanded the action to the lower court.