431 U.S. 494 (1977) (U.S. Supreme Court)
Moore v. City of East Cleveland is a canonical substantive due process decision at the intersection of constitutional law and land-use regulation.
Does a zoning ordinance that narrowly defines "family" to exclude certain close relatives from living together in a single-family dwelling violate the Due Process Clause of the Fourteenth Amendment?
The Fourteenth Amendment's Due Process Clause protects choices concerning family living arrangements as a fundamental aspect of family integrity and autonomy. When government intrudes on the family's composition—particularly where the arrangement is deeply rooted in the Nation's history and tradition—courts must carefully examine the importance of the governmental interests asserted and the fit between those interests and the regulatory means. A zoning ordinance that arbitrarily subdivides the category of relatives to prohibit traditional extended-family households is unconstitutional when its means are not suitably tailored to legitimate aims such as preventing overcrowding, traffic, or burdens on schools. Belle Terre, which upheld limits on unrelated persons living together under rational basis review, does not control when an ordinance restricts living arrangements among close relatives.
Yes. The Supreme Court reversed Mrs. Moore's conviction, holding that East Cleveland's narrow family definition unconstitutionally intruded upon protected choices concerning family living arrangements in violation of the Due Process Clause.
Moore is a landmark affirmation that the Fourteenth Amendment protects family integrity beyond the nuclear family. It narrows Belle Terre's reach by drawing a constitutional distinction between regulating group living by unrelated persons and dictating which close relatives may cohabit. Although the controlling rationale is fragmented (a plurality plus concurrences), the case has become a staple for the proposition that government may not arbitrarily dissect extended families through zoning. For law students, Moore is essential for understanding substantive due process after the Lochner era, the constitutional protection of family autonomy, the tailoring requirement when intimate familial choices are burdened, and how fragmented Supreme Court decisions can still generate binding constitutional constraints on local land-use policy.