Summary of City of Cleburne v. Cleburne Living Center (1985)
Relevant Facts: In 1980, Cleburne Living Center, Inc. submitted a permit application to operate a home for the mentally retarded. The city council of Cleburne voted to deny the special use permit, acting pursuant to a municipal zoning ordinance.
Issue: Under constitutional law, does the denial of the permit violate the Equal Protection rights of Cleburne Living Center, Inc. and its potential residents?
Holding: Yes. Court held that the denial of the special use permit to Cleburne Living Centers, Inc. was premised on an irrational prejudice against the mentally retarded, and hence unconstitutional under the Equal Protection Clause of the Fourteenth Amendment.
Court’s Rationale/Reasoning: In overturning the ordinance, the court noted that it “rests on a bare desire to treat the retarded as outsiders, pariahs who do not belong in the community.” On the bases of both the overall inability to be seen as equal mentally in the eyes of the Court, as well as the legislature’s intent to provide for the needs of the mentally challenged, the acts of discriminating as such was not looked upon favorably. Even the TX legislature has enacted law to help combat discrimination against the mentally retarded. Legislative response has also shows that there is massive public support for such legislation.
The Court should look to the likelihood that governmental action premised on a particular classification is valid as a general matter, not merely to the specifics of the case before us. Because of all the above reasons, such discrimination is something which is not tolerated by the Constitution.
The rational basis for the developmentally disabled gives legislatures the latitude to enact law which should be justified by legitimate reasons for assisting, not neglecting or discriminating. If other multiple-dwelling buildings in town are not regulated by permit, how can this building be mandated to have a permit? There is a difference in the residents of the home as opposed to the general public, but they are not threatened by the home’s existence.
Rule: Strict scrutiny based on discrimination of physically or mentally handicapped. Must have been a justifiable reason for denying the permit.
Important Dicta: While the Court declined to grant the mentally retarded the status of a “quasi-suspect class,” it nevertheless found that the “rational basis” test for legislative action provided sufficient protection against invidious discrimination
Dissenting: Justices Marshall, Brennan, Burger (also concurred in part): Marshall applied the sliding scale principle (substantiality of state interests & reasonableness of means which State sought to advance those interests). Wants more strict scrutiny to be applied.
Concurring: (Justices Stevens, Burger): The reason why the Court has invalidated laws related to discriminating against others is not b/c of intermediate scrutiny, but b/c of the group itself is or is not relevant to a valid public purpose, or to the purpose that the challenged laws purportedly intended to serve. Every law that places the mentally retarded in a special class is not irrational. There are some that are designed to help them despite making those who qualify a separate class.