Monday, November 25, 2013

Familystyle of St. Paul, Inc. v. City of St. Paul case brief

Familystyle of St. Paul, Inc. v. City of St. Paul case brief summary
923 F.2d 91 (8th Cir. 1991)


CASE SYNOPSIS
Appellant service provider to the mentally ill challenged the judgment of the United States District Court for the District of Minnesota that found in favor of appellees, city and state and denied appellant's motion for summary judgment. The action involved group home dispersal requirements contained in a zoning ordinance and the Minnesota Human Services Licensing Act, and alleged violation of the Fair Housing Amendment Act of 1988.

CASE FACTS
Appellant service provider to the mentally ill was denied special use permits for 3 group homes it sought to add to its cluster of 21 such homes in a one and one-half block area. Appellees, city, city council, state attorney general, asserted that the dispersal requirements contained in both the local zoning code and the Minnesota Human Services Licensing Act, Minn. Stat. § 245A.11, subd. 4, legitimately effectuated the state goal of deinstitutionalizing the mentally ill, and did not violate the Fair Housing Amendment Act of 1988 (Act).

DISCUSSION

  • The court held that the dispersal requirement appropriately addressed the need of providing group homes for the mentally ill in residential neighborhoods and that the restrictions did not violate the Act. 
  • The court also rejected appellant's challenges to the restrictions based on discriminatory treatment and disparate impact. 
  • The mentally ill did not constitute a suspect class, and the provisions were rationally related to a legitimate governmental purpose. 
  • The court affirmed the judgment.
CONCLUSION
The court affirmed the judgment rejecting appellant service provider to the mentally ill's challenge to the Minnesota Human Services Licensing Act and city zoning ordinance. The district court properly denied appellant's motion for summary judgment, and held in favor of appellees, state attorney general, city, and city council, that the dispersal of group homes did not violate Fair Housing Amendments Act of 1988 or improperly discriminate.

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