In reviewing the reasonableness of a zoning ordinance, the court's inquiry does not terminate with a finding that it is for an exclusionary purpose. The court must determine further whether the exclusion bears any rational relationship to a legitimate state interest. If it does not, then the zoning regulation is invalid. If, on the other hand, a legitimate state interest is furthered by the zoning regulation, a court must defer to the legislative act.
Appellees brought suit claiming the appellant city's five-year housing and zoning plan was unconstitutional. The questioned plan was adopted to curb the alarming growth of residential houses in the city by limiting the the number of new housing units to a 500 within a five-year period. The district court found in favor of appellees, holding the plan interfered with the right to travel by limiting the population growth of the area.
Is the City’s housing and zoning plan limiting residential construction unconstitutional for being an unreasonable exercise of police power?
On review, the court found that appellees did not have standing to bring a challenge on the grounds that the plan interfered with the right to travel. The court also found that appellant's plan was rationally related to a legitimate state interest. The court held that the zoning ordinance fell within the broad concept of public welfare. The court found that the plan was a legitimate exercise of appellant's police power and did not burden interstate commerce. The court accordingly reversed the order of the district court.