Doe v. City of Butler case brief

Doe v. City of Butler case brief summary
892 F.2d 315 (3d Cir. 1989)

CASE SYNOPSIS

Plaintiffs, battered women, sought review after the United States District Court for the Western District of Pennsylvania denied their application for a preliminary injunction and granted defendant county's cross motion for summary judgment in a class-action challenge to a zoning regulation. U.S.Constitutional amendment I; U.S. Constitutional amendment XIV; the Fair Housing Act, 42 U.S.C.S. §§ 3601-3631.

CASE FACTS
Plaintiff, battered women, who sought to represent battered women in need of temporary shelter, filed a class action challenging a zoning regulation that limited transitional dwellings to a total of six persons. Plaintiffs claimed that the regulation violated the Due Process Clause of the Fourteenth Amendment, associational rights protected by the First Amendment, and the Fair Housing Act, 42 U.S.C.S. §§ 3601-3631. The district court granted defendant county's cross-motion for summary judgment.

DISCUSSION

• The court held that under the deferential rational basis standard, the six-person limit for transitional dwellings in R-2 districts was not arbitrary because it was rationally related to the legitimate government objective of controlling density in a residential neighborhood. 
• The court remanded because the district court failed to consider whether, in residential districts other than R-2, the challenged restriction's relationship to the asserted goal was so attenuated as to render the distinction arbitrary or irrational. 
• The court remanded so the district court could decide whether an across-the-board limit on the number of residents in a transitional dwelling violated the Fair Housing Act.

CONCLUSION
The court vacated and remanded the district court's order granting summary judgment with respect to plaintiffs' due process claims and plaintiffs' Fair Housing Act claims.

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