Belle Terre v. Boraas
**Overview of Belle Terre v. Boraas**
Belle Terre v. Boraas is a significant Supreme Court case centered around zoning laws and constitutional rights, specifically regarding the right to privacy and association. The case originated when a homeowner in Belle Terre, New York, leased a property to six unrelated college students, which led to a citation for violating a local zoning ordinance. The plaintiffs challenged the ordinance, arguing it infringed upon their constitutional rights. In a 7-2 decision, the Court upheld the ordinance, finding that it served a legitimate governmental interest in maintaining a family-friendly environment. Justice William O. Douglas, writing for the majority, applied the rational basis test, asserting that the ordinance was a valid exercise of the village's police powers. Conversely, Justice Thurgood Marshall, in dissent, contended that the ordinance unduly restricted fundamental rights, highlighting the need for a compelling justification for such limitations. This case illustrates the complexities of balancing community interests with individual liberties, and it is often compared to Moore v. City of East Cleveland, which addressed the rights of extended families in similar contexts.
Belle Terre v. Boraas
Date: April 1, 1974
Citation: 616 U.S. 1
Issues: Right of privacy; substantive due process
Significance: The Supreme Court upheld the constitutionality of a local zoning ordinance that prohibited most unrelated groups from living together in a single-unit dwelling.
The owner of a house in the small village of Belle Terre, New York, leased it to six unrelated college students. When cited for violating a zoning ordinance, the owners and tenants went to court, claiming that the ordinance violated their constitutional right of privacy. Speaking for a 7-2 majority, Justice William O. Douglas used the rational basis test of economic and social legislation, and found the ordinance to be a valid exercise of the community’s police power. The ordinance bore a rational relationship with a permissible governmental objective of maintaining a quiet place to raise a family. In dissent, Justice Thurgood Marshall argued that the ordinance infringed on fundamental rights of privacy and association and that the village had the burden of showing a “compelling and substantial” justification for the infringement.
Although upholding the ordinance, the Belle Terre decision demonstrated the Supreme Court’s developing commitment to the doctrine of substantive due process, requiring that any restraints on liberty must be justified by an adequate state interest. The decision should be compared with Moore v. City of East Cleveland (1977), in which the Court struck down an ordinance that had the effect of prohibiting an extended family from living together.