The fact that town officials are motivated by parochial views of local interests that work against a plaintiffs' plan and which may contravene state subdivision laws or local ordinances does not state a claim of denial of substantive due process. Of course, if a zoning decision is based on considerations that violate specific constitutional guarantees, it is invalid; but in all other cases the decision can be said to deny substantive due process only if it is irrational. The same test would be appropriate if the zoning decision were challenged under the Equal Protection Clause of the Fourteenth Amendment, rather than under the Due Process Clause of the Fifth or Fourteenth Amendments.
A landowner, who owned several hundred acres of previously undeveloped land in a village, submitted a site plan to the village for development of a 17-acre parcel into five single-story commercial buildings. The village’s plan committee recommended the plan for approval but the board of trustees disapproved without disclosing any reasons, except from one of the trustees who verbally said that the village has a lot of unused office space. The landowner filed an action against the village under 42 U.S.C.S. § 1983, contending that the village violated the United States Constitution and state law in turning down the plan. The plaintiffs' only federal claims were that they were denied "substantive" and "procedural" due process. The village filed a motion to dismiss the landowner's claim under Fed. R. Civ. P. 12(b)(6). The district court granted the motion and dismissed the landowner's claim. The landowner appealed.
Can the decision of the village’s board of trustees, which did not mention any reason for the denial of the landowner’s plan, be considered irrational, and thus, violated due process?
The court affirmed and held that the village's decision was not irrational and thus did not deny the landowner substantive due process. The Board's decision to approve or disapprove a site plan is a legislative rather than adjudicative decision. The Constitution does not require legislatures to use adjudicative-type procedures to give reasons for their enactments, or to act "reasonably" in the sense in which courts are required to do. The court also held that the hearing was enough to give the plaintiffs all the process that due process in zoning required.