Village of Belle Terre v. Boraas

Facts

Belle Terre is a village on Long Island's north shore, with about 220 homes, 700 people and less than one square mile of land. Its ordinance restricted land use to one-family dwellings. It excluded lodging houses, boarding houses, fraternity houses and multiple-dwelling houses. The ordinance defined a "family" as one or more persons related by blood, adoption or marriage who live and cook together as a single housekeeping unit. It also treated up to two people living together as a family even if they were not related. The Dickmans owned a house in the village. In December 1971 they leased it for 18 months to Michael Truman. Bruce Boraas later became a co-lessee, and Anne Barish then moved in with three others. All six were students at nearby State University at Stony Brook, and none was related to any other by blood, adoption, or marriage. The village served the Dickmans with an "Order to Remedy Violations" of the ordinance. During the litigation the lease expired and was extended, one tenant moved out, and then the other five students left. The owners then held the home out for sale or rent, including to student groups.

Issues

1. Is the case still a live controversy, even though the student tenants have left the house and the owners have a continuing interest in the value of their rental property?
2. Does a village zoning ordinance that limits a household of unrelated people to two, while placing no cap on people related by blood, adoption or marriage, violate the Constitution, including equal protection and the rights of travel, association and privacy?

Holding

The case was not moot, and the ordinance is valid. It involves no fundamental right, it draws a line that is a legislative judgment, and it rationally serves the permissible goal of a quiet, family-oriented area. The Court of Appeals' judgment was reversed.