City of Edmonds v. Oxford House, Inc.

1995-05-15

Headline: Court rules zoning ‘family’ definitions are not exempt from the Fair Housing Act, limiting the occupancy‑exemption and making it easier for group homes for people with disabilities to seek housing accommodations.

Holding: The Court holds that a municipal rule defining who qualifies as a “family” is not exempt under the FHA’s maximum‑occupancy exemption, which applies only to numerical overcrowding limits.

Real World Impact:

Makes family‑definition zoning rules subject to Fair Housing Act review.
Helps group homes for people with disabilities seek reasonable accommodations.
Limits cities’ ability to shield family rules from federal disability protections.

Topics: disability housing, zoning rules, group homes, occupancy limits, reasonable accommodation

Summary

Background

Oxford House opened a group home in Edmonds for about 10 to 12 adults recovering from alcoholism and drug addiction. Edmonds’ zoning code allows only “families” in single‑family neighborhoods, defining family as people related by blood, adoption, or marriage of any number, or a group of five or fewer unrelated people. City officials issued citations because the house had more than five unrelated residents, and Oxford House and the United States sued under the Fair Housing Act seeking a reasonable accommodation so the home could remain.

Reasoning

The Court considered whether the FHA’s statutory exemption for “restrictions regarding the maximum number of occupants permitted to occupy a dwelling” shields the City’s family‑definition rule. The Court held that the exemption covers numerical occupancy ceilings aimed at preventing overcrowding (for example, limits tied to floor area or room size). By contrast, rules that define who counts as a “family” to preserve neighborhood character are not the same as total occupancy limits and therefore are not exempt. The Supreme Court affirmed the Ninth Circuit and left the merits of the discrimination and accommodation claims to the lower courts.

Real world impact

The decision means cities cannot automatically hide family‑composition zoning rules behind the occupancy exemption. Group homes for people with disabilities may press FHA reasonable‑accommodation claims to stay in single‑family areas. The ruling is a threshold statutory interpretation; it does not decide whether Edmonds actually violated the FHA, and lower courts must determine liability and remedies.

Dissents or concurrances

Justice Thomas, joined by Justices Scalia and Kennedy, dissented, arguing the city’s five‑unrelated‑person limit does qualify as a restriction regarding maximum occupants and therefore should be exempt under the plain statutory text.