City of Edmonds v. Oxford House, Inc.
514 U.S. 725 (1995)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A zoning ordinance defining "family" to cap the number of unrelated persons who may live together is a family composition rule, not a maximum occupancy restriction. As such, it is not exempt from scrutiny under the Fair Housing Act (FHA) through the exemption provided in 42 U.S.C. § 3607(b)(1).
Facts:
- Oxford House opened a group home for 10 to 12 adults recovering from alcoholism and drug addiction in a neighborhood in the City of Edmonds, Washington.
- The neighborhood was zoned for single-family residences.
- The City of Edmonds' zoning code defined 'family' as persons related by genetics, adoption, or marriage, or a group of five or fewer unrelated persons.
- Because the Oxford House residence housed more than five unrelated individuals, it was in violation of the city's zoning code.
- For the purposes of the litigation, the parties stipulated that the residents of Oxford House are 'handicapped persons' within the meaning of the Fair Housing Act (FHA).
- The City of Edmonds issued criminal citations to the owner and a resident of the house for violating the zoning ordinance.
- Oxford House requested a 'reasonable accommodation' under the FHA, asking the City to allow the group home to continue operating with its current number of residents, but the City declined.
- Oxford House asserted that 8 to 12 residents were necessary for the group home to be financially and therapeutically viable.
Procedural Posture:
- The City of Edmonds sued Oxford House in the U.S. District Court for the Western District of Washington, seeking a declaration that its zoning code was not constrained by the FHA.
- Oxford House counterclaimed, alleging the City failed to make a reasonable accommodation under the FHA.
- The United States filed a separate FHA action against the City, which was consolidated with the initial case.
- The District Court granted summary judgment for the City of Edmonds, holding its 'family' definition was exempt from the FHA under § 3607(b)(1).
- Oxford House and the United States, as appellees, appealed to the U.S. Court of Appeals for the Ninth Circuit.
- The Ninth Circuit reversed the District Court's judgment, holding that the exemption did not apply.
- The City of Edmonds, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a local zoning ordinance that defines 'family' as persons related by genetics, adoption, or marriage, or a group of five or fewer unrelated persons, qualify for the Fair Housing Act's exemption for 'any reasonable... restrictions regarding the maximum number of occupants permitted to occupy a dwelling' under 42 U.S.C. § 3607(b)(1)?
Opinions:
Majority - Justice Ginsburg
No. A zoning rule that defines who may compose a family unit is a family composition rule, not a maximum occupancy restriction, and therefore does not qualify for the Fair Housing Act's exemption under § 3607(b)(1). The Court distinguishes between two types of municipal housing rules: (1) family composition rules, which are land-use restrictions designed to preserve the character of a neighborhood by defining who may live together as a 'family,' and (2) maximum occupancy restrictions, which cap the total number of occupants a dwelling can house, typically based on floor space, to prevent overcrowding and protect health and safety. The exemption in § 3607(b)(1) was intended to cover only the latter. Edmonds' ordinance is a classic family composition rule because it places no limit on the number of related people who can live together; its primary purpose is to describe 'family living,' not to set a ceiling on the number of occupants a dwelling can safely contain. The numerical limit on unrelated persons is merely a component of the family definition and does not convert the entire ordinance into a maximum occupancy restriction. Exemptions to broad remedial statutes like the FHA must be construed narrowly to preserve the primary purpose of the policy.
Dissenting - Justice Thomas
Yes. The City of Edmonds' zoning code provision qualifies for the FHA's exemption because it plainly falls within the statutory text. The statute exempts 'any reasonable... restrictions regarding the maximum number of occupants permitted to occupy a dwelling.' The Edmonds ordinance establishes a specific number—five—as the maximum number of unrelated persons permitted to live in a single-family dwelling. This is clearly a restriction 'regarding' the maximum number of occupants. The majority errs by inventing a distinction between 'family composition rules' and 'maximum occupancy restrictions' that is not present in the statute's text. The plain language does not require the restriction to be an absolute cap applicable in all situations. Furthermore, because zoning and land use are areas traditionally regulated by the states, federal statutes that intrude upon this power, like the FHA, should not have their exemptions read narrowly.
Analysis:
This decision significantly limits the ability of municipalities to use 'single-family' zoning ordinances to exclude group homes for individuals protected by the FHA. By distinguishing between family composition rules and true maximum occupancy restrictions, the Court ensures that such zoning ordinances are not automatically exempt from the FHA's 'reasonable accommodation' requirement. The ruling prevents cities from using a numerical cap on unrelated residents as a shield against FHA scrutiny. Consequently, municipalities with similar zoning laws must now engage in a case-by-case analysis to determine if they are required to accommodate group homes for people with disabilities, rather than relying on a blanket exemption.
Unlock the full brief for City of Edmonds v. Oxford House, Inc.