City of Ladue v. Horn
720 S.W.2d 745 (1987)
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Rule of Law:
A municipal zoning ordinance that restricts occupancy in single-family residential zones to individuals related by blood, marriage, or adoption is a constitutional exercise of a municipality's police power because it is rationally related to the legitimate state objective of preserving the character of a traditional family neighborhood.
Facts:
- The City of Ladue had a zoning ordinance that defined 'family' for the purposes of its single-family residential zones as '[o]ne or more persons related by blood, marriage or adoption, occupying a dwelling unit as an individual housekeeping organization.'
- In July 1981, Joan Horn and E. Terrence Jones, an unmarried couple, purchased a seven-bedroom house located within a single-family residential zone in Ladue.
- Residing in the home with Horn and Jones were Horn's two children and Jones's one child.
- The household members functioned as a single family unit: Horn and Jones shared a common bedroom, maintained a joint checking account for household expenses, ate meals together, entertained together, and disciplined each other's children.
- The City of Ladue made demands upon Horn and Jones to vacate their home, asserting that their household did not constitute a 'family' under the zoning ordinance.
- Horn and Jones refused to vacate the home.
Procedural Posture:
- The City of Ladue sued Joan Horn and E. Terrence Jones in the trial court, seeking an injunction to prohibit them from occupying their home in violation of the city's zoning ordinance.
- Defendants Horn and Jones filed a counterclaim, asking the court to declare the zoning ordinance constitutionally void.
- The trial court entered a permanent injunction in favor of the City of Ladue and dismissed the defendants' counterclaim.
- The trial court stayed the enforcement of its injunction pending the outcome of an appeal.
- Defendants Horn and Jones (appellants) appealed the trial court's judgment to the Missouri Court of Appeals (the intermediate appellate court).
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Issue:
Does a municipal zoning ordinance that defines 'family' as persons related by blood, marriage, or adoption, thereby prohibiting an unmarried couple and their children from residing together in a single-family zone, violate the Due Process or Equal Protection Clauses of the United States and Missouri Constitutions?
Opinions:
Majority - Crandall, J.
No. The zoning ordinance does not violate the United States or Missouri Constitutions. Because the ordinance involves economic and social legislation and does not impinge upon a fundamental right or involve a suspect classification, it is subject to the rational basis test. Citing Village of Belle Terre v. Boraas, the court found the ordinance is a permissible exercise of the city's police power, rationally related to the legitimate state objective of laying out zones to promote family values, quiet seclusion, and other benefits of a traditional family-oriented neighborhood. The court distinguished Moore v. City of East Cleveland, which unconstitutionally interfered with the composition of a traditional family, whereas Ladue's ordinance merely defines the family unit in a traditional manner. The court deferred to Ladue's legislative judgment in choosing this definition and found no state or federal constitutional violation.
Analysis:
This decision reinforces the significant deference courts grant to municipalities in enacting zoning ordinances aimed at preserving community character. It affirms the principle from Village of Belle Terre that defining a 'family' based on biological or legal relationships is constitutionally permissible under the rational basis test. The ruling solidifies the legal distinction between ordinances that regulate households of unrelated individuals (permissible) and those that intrude upon the composition of traditional, extended families (impermissible, per Moore). This case demonstrates that courts may be reluctant to expand the definition of 'family' in zoning contexts to include 'functional' or 'conceptual' families, thereby privileging traditional family structures in land use planning.
