City of Cleburne v. Cleburne Living Center
Citation
473 U.S. 432 (1985)
Facts
The city of Cleburne denied a special use permit for the operation of a group home for intellectually disabled individuals, citing concerns about the home’s location and the residents’ characteristics. The Cleburne Living Center challenged the denial as unconstitutional discrimination.
Issue
Whether the Equal Protection Clause is violated when a city denies a special use permit for a group home for the intellectually disabled based on irrational fears and negative attitudes.
Holding
The Supreme Court struck down the denial of the permit, holding that even under rational basis review the ordinance failed because it rested on bare negative attitudes or fear toward the intellectually disabled.
Rule
Even under rational basis review, a law fails if it rests on bare negative attitudes or fear; mental disability is not a quasi-suspect class, but courts apply “rational basis with bite” in this context.