Familystyle of St. Paul, Inc. v. City of St. Paul
923 F.2d 91 (1991)
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Rule of Law:
A state law or municipal ordinance that requires licensed residential group homes for the mentally ill to be dispersed by a minimum distance does not violate the Fair Housing Amendments Act of 1988. Such a requirement is permissible if it is rationally related to the legitimate governmental interest of deinstitutionalization and integrating the mentally ill into the community.
Facts:
- Familystyle of St. Paul, Inc. operates residential group homes for individuals with mental illness.
- Familystyle maintained a campus of 21 group homes, housing 119 people, clustered within a one-and-a-half-block area in St. Paul, Minnesota.
- The company sought special use permits to add three more houses to this same concentrated area.
- The City of St. Paul issued temporary permits on the condition that Familystyle would work to disperse its facilities, a condition Familystyle failed to meet.
- A Minnesota state statute and a St. Paul city zoning ordinance both require such residential facilities to be located at least a quarter-mile apart.
- Following Familystyle's failure to meet the dispersal condition, the City of St. Paul denied the renewal of the permits for the three additional houses, citing the spacing requirements.
Procedural Posture:
- Familystyle of St. Paul, Inc. filed suit against the City of St. Paul and the State of Minnesota in the United States District Court for the District of Minnesota.
- Familystyle sought a declaratory judgment that the state and city dispersal requirements violated the Fair Housing Amendments Act of 1988.
- Both parties moved for summary judgment.
- The district court denied Familystyle's motion and granted summary judgment in favor of the City of St. Paul and the State of Minnesota.
- Familystyle, as the plaintiff-appellant, appealed the district court's judgment to the U.S. Court of Appeals for the Eighth Circuit.
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Issue:
Do a state law and city ordinance that require licensed residential facilities for the mentally ill to be located at least a quarter-mile apart violate the Fair Housing Amendments Act of 1988 by discriminating on the basis of handicap?
Opinions:
Majority - Wollman, J.
No. The Minnesota statute and St. Paul ordinance requiring quarter-mile spacing between residential facilities for the mentally ill do not violate the Fair Housing Amendments Act (FHAA). The court reasoned that the goals of the FHAA (preventing discrimination) and the state's dispersal policy (promoting deinstitutionalization) are compatible, not in conflict. The purpose of the spacing requirement is to integrate the mentally ill into mainstream society and prevent the creation of 'enclaves' or 'ghettos' that would replicate the isolating environment of institutions. Applying a rational basis standard of review as established in City of Cleburne, the court found that deinstitutionalization is a legitimate governmental purpose, and the dispersal requirement is a rational means of achieving that purpose. The court concluded that rather than being discriminatory, the policy prevents the segregation of the mentally ill.
Analysis:
This decision establishes that facially neutral zoning ordinances aimed at the integration of handicapped individuals can withstand challenges under the Fair Housing Amendments Act. It clarifies that the FHAA's prohibition on discrimination does not invalidate all regulations that may limit housing choices, particularly when those regulations serve a legitimate therapeutic or social integration purpose. The court's application of the rational basis test from Cleburne in a Title VIII disparate impact case sets a precedent that gives significant deference to state and local governments in regulating the location of group homes. This ruling empowers municipalities to enforce dispersal requirements to prevent the concentration of such facilities, balancing the goals of anti-discrimination and community integration.
