City of Cleburne v. Cleburne Living Center, Inc., 473 U.S. 432 (1985)
Author: White (majority) Outcome: Respondents win ($d = 1$: ordinance invalid as applied) Concurrences: Stevens (joined by Burger) Dissents: Marshall (joined by Brennan and Blackmun)
1. Holding ($H_t$)
"Requiring a special use permit for the proposed group home here deprives respondents of the equal protection of the laws, and thus it is unnecessary to decide whether the ordinance's permit requirement is facially invalid where the mentally retarded are involved." (p. 447)
As constraint on admissible $(w, c)$: The holding rules out any decision rule that would allow a zoning ordinance to require a special use permit for a group home for the mentally retarded when similar uses (e.g., boarding houses, nursing homes) do not require such a permit, unless there is a rational basis for the distinction. The weight on irrational prejudice against the mentally retarded must be zero; any rule that rests on such prejudice is invalid.
What the holding does NOT constrain:
- Whether the ordinance is facially invalid for all applications to the mentally retarded
- The validity of requiring special use permits for other uses listed in the ordinance
- The applicability of heightened scrutiny to classifications based on mental retardation
2. Fact vector $z_t$
2a. Raw salient facts
- Special use permit required: The city required a special use permit for the group home for the mentally retarded, unlike other similar uses in the same zoning area (p. 447). Favors: plaintiff.
- Negative attitudes and fears: The City Council's decision was influenced by negative attitudes and fears of nearby property owners (p. 448). Favors: plaintiff.
- Location concerns: The facility's location near a junior high school and on a flood plain were cited as concerns (p. 448-449). Favors: government.
- Density and size concerns: Concerns about the size of the home and the number of residents were raised, but similar concerns were not applied to other permitted uses (p. 449). Favors: plaintiff.
- Legal responsibility concerns: The city expressed concerns about legal responsibility for actions of the mentally retarded residents (p. 449). Favors: government.
2b. Dimension mapping
| Dimension | Value | Raw fact(s) mapped | Textual basis |
|---|---|---|---|
| D1 Facial classification | Low | Special use permit required | Permit requirement based on mental retardation (p. 447) |
| D2 Protected trait | Disability (mental retardation) | Special use permit required | Classification based on mental retardation (p. 447) |
| D3 Intent evidence | High | Negative attitudes and fears | Decision influenced by negative attitudes (p. 448) |
| D4 Interest strength | Weak | Location concerns; density and size concerns | Concerns not applied to similar uses (p. 448-449) |
| D5 Means-ends fit | Poor | Density and size concerns; legal responsibility concerns | No rational basis for differential treatment (p. 449) |
| D6 Stigma / caste risk | High | Negative attitudes and fears | Decision based on irrational prejudice (p. 450) |
| D7 Institutional setting | Zoning | Special use permit required | Zoning ordinance context (p. 447) |
| D8 Precedent density | Low | — | No established precedent for heightened scrutiny for mental retardation |
Unmapped facts:
- Flood plain location does not map neatly to any existing dimension. It is a factual concern that the Court found irrelevant to the differential treatment of the group home.
Notable: The Court emphasizes that the ordinance's application rests on irrational prejudice against the mentally retarded, highlighting the importance of D6 (stigma/caste risk).
3. Treatment of prior holdings ($\mathcal{F}_t$ update)
Plyler v. Doe (1982)
- Status: Relied on. The Court references Plyler's discussion of the Equal Protection Clause's requirement that all persons similarly situated should be treated alike (p. 439).
- Characterization: Plyler is used to support the principle that classifications must be rationally related to a legitimate state interest.
- Model interpretation: Reinforces the constraint that laws must have a rational basis, particularly when affecting vulnerable groups.
Frontiero v. Richardson (1973)
- Status: Distinguished. The Court notes that gender classifications often bear no relation to ability, contrasting with mental retardation, which can be relevant (p. 442).
- Characterization: Frontiero is used to illustrate when heightened scrutiny is appropriate, but the Court declines to extend it to mental retardation.
- Model interpretation: Limits the extension of heightened scrutiny to mental retardation, maintaining a broader set of admissible rules for such classifications.
4. Overruling (constraint removal at cost $C$)
No overruling in this case. The Court explicitly declines to extend heightened scrutiny to classifications based on mental retardation, maintaining the rational basis review for such cases.
5. Breadth
Narrow reading (what the Court explicitly holds):
- The ordinance's application to require a special use permit for the group home for the mentally retarded is invalid due to lack of rational basis.
- Limited to the specific application in this case; does not address the ordinance's facial validity.
Broad reading (what the reasoning supports):
- The reasoning could support invalidating similar ordinances that rest on irrational prejudice against the mentally retarded.
- Suggests that any differential treatment of the mentally retarded must be carefully justified.
Breadth ambiguity:
- The opinion leaves open whether other applications of the ordinance might be valid or whether similar ordinances elsewhere might withstand scrutiny.
- The scope of rational basis review in cases involving mental retardation remains somewhat ambiguous.
6. Concurrences / dissents (alternative admissible theories)
Stevens, J., concurring (joined by Burger, C.J.)
- Alternative constraint structure: Stevens emphasizes a "continuum of judgmental responses" rather than rigid tiers of scrutiny (p. 451). He suggests a rational basis test that includes legitimacy and neutrality.
- Key disagreement: Disagrees with the rigid application of scrutiny tiers, advocating for a more nuanced approach that considers the context and purpose of the classification.
Marshall, J., concurring in the judgment in part and dissenting in part (joined by Brennan and Blackmun, JJ.)
- Alternative constraint structure: Marshall argues for heightened scrutiny for classifications based on mental retardation, emphasizing the history of discrimination and the importance of the interests at stake (p. 455).
- Key disagreement: Disagrees with the majority's application of rational basis review, arguing that the ordinance should be invalidated on its face due to its overbroad and discriminatory nature.
7. Reasoning revealing implicit weights on dimensions
Rational basis review (D5 weight is low):
"The State may not rely on a classification whose relationship to an asserted goal is so attenuated as to render the distinction arbitrary or irrational." (p. 446)
The Court emphasizes that the ordinance lacks a rational basis, indicating a low weight on means-ends fit (D5) when the classification is based on irrational prejudice.
Stigma and prejudice (D6 weight is high):
"The short of it is that requiring the permit in this case appears to us to rest on an irrational prejudice against the mentally retarded..." (p. 450)
The Court highlights the high weight on stigma and prejudice (D6), invalidating the ordinance due to its reliance on irrational fears and biases.
Legislative flexibility (D4 weight is low):
"Governmental bodies must have a certain amount of flexibility and freedom from judicial oversight in shaping and limiting their remedial efforts." (p. 444)
The Court acknowledges the need for legislative flexibility, but finds that the ordinance's application in this case does not meet even the low threshold required for rational basis review.