Cleburne v. Cleburne Living Center

Cleburne v. Cleburne Living Center, 473 U.S. 432 (1985), is a landmark decision of the United States Supreme Court.

The City of Cleburne, Texas required a special use permit for a group home for individuals with intellectual disabilities, though other group homes (for fraternities, hospitals, etc.) did not require permits. The operator of the proposed home challenged the zoning decision as violating the Equal Protection Clause and seeking heightened scrutiny for disability classifications.

Significance

Justice White’s 8-1 opinion struck down the zoning law under rational basis review. The Court declined to treat disability as a suspect or quasi-suspect classification requiring heightened scrutiny. However, the Court applied rational basis with ‘bite,’ finding that the city’s justifications — including concerns about the residents’ supposed abilities and negative attitudes of neighbors — rested on irrational prejudice. Cleburne is notable for applying a more searching form of rational basis review to discrimination against people with disabilities.

Category

US Federal Case Law