Moore v. City of East Cleveland
Moore v. City of East Cleveland is a significant Supreme Court case that addresses the intersection of zoning laws and family rights. The case arose when Inex Moore, a grandmother, was penalized for living with her grandsons in a neighborhood that enforced a zoning ordinance limiting residences to single families. This ordinance defined "family" in a narrow manner that excluded Moore's household arrangement, leading to her incarceration for noncompliance. The Supreme Court ultimately ruled by a narrow 5-4 decision that the ordinance violated the due process clause of the Fourteenth Amendment. Justice Lewis F. Powell, Jr. highlighted the importance of personal choice in familial matters and argued that the definition of family should be broader, reflecting diverse living arrangements, such as extended families. This ruling not only protected the rights of individuals to choose their family structures but also influenced future legal interpretations of family privacy and zoning regulations. The case underscores the ongoing dialogue about the definitions of family and the rights of individuals within the context of community regulations.
Moore v. City of East Cleveland
Date: May 31, 1977
Citation: 431 U.S. 494
Issues: Right of privacy; substantive due process
Significance: The Supreme Court used the doctrine of substantive due process to strike down a local zoning ordinance that prohibited extended families from living together in a single-unit residence.
A residential suburb of Cleveland, Ohio, wanting to maintain its character as a single-family neighborhood, enacted a zoning ordinance that restricted each dwelling to a single family. The ordinance defined a family so narrowly that it did not allow Inex Moore, a grandmother, to live with her two grandsons. When Moore refused to comply with the ordinance, she was sentenced to five days in jail and fined twenty-five dollars.
By a 5-4 vote, the Supreme Court held that the ordinance violated the due process clause of the Fourteenth Amendment. In a plurality opinion, Justice Lewis F. Powell, Jr., emphasized the importance of “personal choice in matters of marriage and the family,” and he argued that the Fourteenth Amendment protects those liberties that are “deeply rooted in our history and tradition.” He concluded that this tradition was broad enough to encompass various forms of extended families. Powell’s opinion significantly extended the scope of the substantive due process approach, and his history and tradition standard has often served as a rationale for subsequent decisions.