The following cases involve rehabilitation facilities in the context of land use law and disability:
City of Edmonds v. Oxford House Inc., 514 U.S. 725 (1995)
Tags
- Family
- Group Home
- Rehabilitation facility
- Halfway house
- FHA
- Reasonable accommodation
Story
The City of Edmonds’ zoning code contained a provision defining family in areas zoned for single-family use. The code defined “family” as “(1) an individual or two or more persons related by genetics, adoption, or marriage; or (2) a group of five or fewer persons not so related.” Oxford House, Inc. opened a group home for 10 to 12 unrelated adults recovering from alcoholism or drug addiction, though the property was located in a single-family zoning district. The city issued criminal citations to the owner and one resident for allegedly violating the zoning restriction. Oxford House asked to be allowed to continue its operations in the same dwelling as a “reasonable accommodation” under the FHA. The City denied their request and passed an ordinance listing groups homes as permitted uses in multi-family and general commercial zones.
Legal Claims
Edmonds sought a declaration that the FHA did not apply to the city's zoning code. The District Court held that the city's zoning code rule defining family was exempt from the FHA under as a reasonable restriction regarding the maximum number of occupants permitted to occupy a dwelling. The 9th Circuit reversed the District Court and Edmonds appealed to the Supreme Court.
Holding/Reasoning
The Supreme Court, in a 6-3 opinion, held that the definition of “family” was not a maximum occupancy restriction, and thus not exempt from the FHA. The court held that the provision was a family composition rule and was not a maximum occupancy restriction exempt from FHA scrutiny. The definition of family may have capped the number of unrelated persons allowed to occupy a single-family dwelling at five, but it did not cap the total number of people permitted to live in such a dwelling. The court also said the ordinance was intended to foster the “family character of a neighborhood,” so it described family living arrangements, not living space per occupant.