City of Baton Rouge/Parish of East Baton Rouge v. Myers
145 So. 3d 320
| La. | 2014Background
- City-Parish sued Myers to halt alleged violation of UDC, seeking injunctive relief for occupancy in a single-family Al district.
- Myers admitted ownership, disputed occupancy and challenged UDC’s definition of “family” as unconstitutional on various grounds.
- District court dismissed injunctive relief and held the UDC’s “family” definition unconstitutional and unenforceable; issued a declaratory judgment.
- City-Parish sought review, including a writ for suspensive appeal; court granted review and remanded for proceedings consistent with its rulings.
- On appeal, the court reversed the district court’s unconstitutionality ruling and denied suspensive appeal, remanding for further proceedings on enforcement and injunctive relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of UDC’s “family” definition | City-Parish contends the definition is unconstitutional, excluding nontraditional families. | Myers argues the definition is vague and violates privacy and equal protection. | UDC definition not unconstitutional; vagueness rejected. |
| Standing to challenge nonparties’ rights under FHA | City-Parish asserts rights of tenants/families are affected by the ordinance. | Myers argues plaintiffs lack standing to raise claims of third parties. | Tenant-related claims lack standing; only personal claims by Myers addressed. |
| Rational basis and equal protection analysis of occupancy limits | City-Parish argues limits are irrational and discriminatory against nontraditional families. | Myers contends classifications are rational and uniformly applied. | No demonstrated equal protection violation; ordinance rationally related to health, safety, welfare. |
| Suspensive appeal of declaratory judgment | City-Parish seeks suspensive appeal under Article 2123 and 13:4431. | Myers argues inappropriate remedy; appeals governed by Article 2123. | Suspensive appeal properly required; reversed denial and remanded for enforcement and further proceedings. |
Key Cases Cited
- Village of Belle Terre v. Boraas, 416 U.S. 1 (U.S. 1974) (zoning rationally related to permissible state objectives; states may exclude unrelated individuals)
- Village of Euclid v. Ambler Realty Co., 272 U.S. 365 (U.S. 1926) (established deferential zoning standard; deference to legislative judgments)
- Moore v. City of East Cleveland, 431 U.S. 494 (U.S. 1977) (distinguishes occupancy limits that deeply intrude on family choice; strict scrutiny where fundamental rights implicated)