Facts: A Borough of Glassboro ordinance limits residence in certain districts to stable and permanent “single housekeeping units” that constitute either a “traditional family unit” or its functional equivalent. The Borough conceded that the ordinance was to prevent groups of college students from living together.
Issue: Whether a group of ten unrelated college students constitute a “family” within the definition of a restrictive zoning ordinance.
Procedural History: The Chancery Division concluded that the relationship and living arrangements among Vallorosi and the other college students demonstrated the “generic character” of a family. The Appellate Division affirmed.
Holding: Affirmed the judgment of the Appellate Division.
Reasoning: Vallorosi and the other students often ate meals together, cooked for each other, and shared the household chores, grocery shopping, and yard work. In addition, a common checking account paid for food and other bills and they shared the use of a telephone. Although Vallorosi and the students are uncertain of living arrangements after graduation, their relationship “shows stability, permanency and can be described as the functional equivalent of a family.”
Facts: The Village of Belle Terre is located on Long Island’s north shore and is inhabited by 700 people. Belle Terre restricts land use to one-family dwellings and Boraas became a colessee with five other college students. The Village of Belle Terre defines “family” as “One or more persons related by blood, adoption, or marriage, living and cooking together as a single housekeeping unit, exclusive of household servants. A number of persons but not exceeding two (2) living and cooking together as a single housekeeping unit though not related by blood, adoption, or marriage shall be deemed to constitute a family.”
Issue: Whether the zoning ordinance interferes with certain fundamental rights such as the right to travel, immigrate to and settle within a State, barring people who are uncongenial to the present residents…and that the ordinance is antithetical to the Nation’s experience, ideology and self-perception as an open, egalitarian, and integrated society.
Holding: The zoning ordinance is upheld.
Reasoning: Zoning ordinances are legitimate police powers of the state, there is no fundamental right involved, and therefore, the zoning ordinance only needs to be “reasonable, not arbitrary” and bear a “rational relationship to a permissible state objective.”
Dissent (Justice Marshall): The classification burdens the students’ fundamental rights of association and privacy guaranteed by the First and Fourteenth Amendments. Therefore, the ordinance should not just be subjected to a rational basis review. Also, the Village of Belle Terre is free to limit the density of occupancy but cannot limit the density only in homes occupied by unrelated persons – the Village is then regulating the way people choose to associate with each other within the privacy of their own homes.
Facts: Braschi lived with another male Blanchard in a rent-controlled apartment in New York for eleven years. Blanchard died in 1986 and subsequently, Stahl Associates Company served notice on Braschi that he was a mere licensee with no right to occupy the apartment since only Blanchard was the tenant of record.
Procedural History: The Supreme Court concluded that Braschi was a “family member” within the meaning of the rent control regulation based on the interdependent nature of Braschi’s 10 year relationship with Blanchard. The Appellate Division reversed when it concluded that the regulation provides non-eviction protection only to “family members within traditional, legally recognized familial relationships.”
Issue: Whether Braschi demonstrated a likelihood of success on the merits that he would be included in the term “family” as used within the rent-control code.
Holding: Yes, Braschi demonstrated this likelihood. Reversed the Appellate Division decision and remitted.
Reasoning: “Family” was not defined in the rent-control code. The rent-control regulations were intended to protect against sudden eviction and “prevent exactions of unjust, unreasonable, and oppressive rents.” This intended protection should not rest on “fictitious legal distinctions or genetic history, but instead should find its foundation in the reality of family life.”
Dissent: The plurality adopted a definition of family which extends the language of the regulation. The court “has expanded the class indefinitely to include anyone who can satisfy an administrator that he or she had an emotional and financial ‘commitment’ to the statutory tenant.”